USCA Case #21-1075 Document #1916126 Filed - Children's ...

United States Court of Appeals For the District of Columbia Circuit

No. 21-1075 (FCC-86FR11432)

Petition for Review of Order Issued by the Federal Communications Commission

Children’s Health Defense, Dr. Erica Elliot, Ginger Kesler, Angela Tsiang, Jonathan Mirin, Petitioners

v. Federal Communications Commission and United States of America,

Respondents

DEFERRED JOINT APPENDIX

VOLUME 4

Robert F. Kennedy, Jr. Children’s Health Defense 48 Dewitt Mills Road 1227 North Peachtree Pkwy, Suite 202 Peachtree City, Georgia 30269 NY Bar No. 1999994 EMAIL: [email protected] TEL: 512.888.1112 FAX: 512.692.2522

W. Scott McColloughMcCollough Law Firm, P.C.2290 Gatlin Creek Rd.Dripping Springs, TX 78620Texas Bar No. 13434100EMAIL: [email protected]: 512.888.1112FAX: 512.692.2522

Counsel for all Petitioners

USCA Case #21-1075 Document #1916126 Filed: 09/29/2021 Page 1 of 276

DEFERRED APPENDIX TABLE OF CONTENTS

Item# Type/Title Filer Date JA Page

VOLUME 1 1. Updating the Commission’s

Rule for Over-the-Air Reception Devices, 36 FCC Rcd 537 (Jan. 7, 2021) (“Order”)

FCC Jan.7, 2021 JA0001

2. Updating the Commission’s Rule for Over-the-Air Reception Devices, 34 FCC Rcd 2695 (Apr. 12, 2019) (“NPRM”)

FCC Apr 12, 2019 JA0035

3. Ex Parte Children’s Health Defense

Apr 17, 2020 JA0057

4. Declaration of Dafna Tachover in Support of Supplement to Written Ex Parte by Children’s Health Defense and Exhibit 1; May 21, 2019

Children’s Health Defense

May 19, 2020 JA0079

VOLUME 2 5. Part 1 -Tachover Declaration

Exhibit 2: List of Objecting Persons Joining in CHD Comment


May 19, 2020 JA0089

VOLUME 3

5. Part 2 -Tachover Declaration Exhibit 2: List of Objecting Persons Joining in CHD Comment


May 19, 2020 JA505

VOLUME 4

6. Biological And Health Effects Of Microwave Radio Frequency Transmissions A

Kevin Mottus Oct.2, 2020 JA0506


iii

Review Of The Research Literature, Dr. Paul Dart (2013)

7. Diplomats’ Mystery Illness and Pulsed Radiofrequency/ Microwave Radiation, Professor Beatrice Alexandra Golomb, MD, PhD (2018)

Kevin Mottus Sep 14, 2020 JA0584

8. EUROPAEM EMF Guideline 2016 for the prevention, diagnosis and treatment of EMF-related health problems and illnesses (2016)

Kevin Mottus Sep. 14, 2020 JA0648

9. Guideline of the Austrian Medical Association for the diagnosis and treatment of EMF-related health problems and illnesses (EMF syndrome) (2011)


VOLUME 5

10. Electromagnetic Hypersensitivity, A Summary by Dr Erica Mallery-Blythe (2014)

Kevin Mottus Oct. 5, 2020 JA0702

11. Electrohypersensitivity as a Newly Identified and Characterized Neurologic Pathological Disorder: How to Diagnose, Treat, and Prevent It, Prof. Dominique Belpomme, MD (2020)


12. Council of Europe, The potential dangers of electromagnetic fields and their effect on the environment (2011)



iv

13. Microwave frequency electromagnetic fields (EMFs) produce widespread neuropsychiatric effects including depression; Dr. Martin Pall (2015)


VOLUME 6

14. Pre-Filed Testimony Of Richard Conrad, Ph.D


15. Ex Parte The Wireless Internet Service Providers Association (WISPA)

Mar. 27, 2019 JA1022

16. Comment The Wireless Internet Service Providers Association (WISPA)

Jun. 3, 2019 JA1029

17. Ex Parte (Letter) The Wireless Internet Service Providers Association (WISPA)

Aug. 27, 2018 JA1051

18. Reply Comment The Wireless Internet Service Providers Association (WISPA)

Jun. 17, 2020 JA1057

VOLUME 7

19. Ex Parte The Wireless Internet Service Providers Association (WISPA)

Dec. 14, 2020 JA1080


v

20. Petition For Declaratory Ruling

WISP.net; Rodecker Slater, LLC

Sep. 18, 2019 JA1086

21. Declaration of David Rodecker; Petition For Declaratory Ruling

WISP.net; Rodecker Slater, LLC

Sep. 18, 2019 JA1113

22. Comment Cindy Sallis Jun. 18, 2019 JA1121 23. Comment Linda Kurtz Jun. 18, 2019 JA1123 24. Comment Brigitte Otto Jun. 18, 2019 JA1125 25. Comment Peg Peterson Jun.17, 2019 JA1127 26. McKenzie Jennings Comment Susan Jennings,

McKenzie Jennings, Michael Jennings

Oct. 2, 2019 JA1129

27. Comment Shelley Masters Jun. 18, 2019 JA1131 28. Comment Debra R. Van

Dusen Oct.15, 2019 JA1133

29. Reply Comment Matina Johnson Jun. 17, 2019 JA1135 30. Comment Alexandra

Ansell Jun. 18, 2019 JA1138

31. Comment Stephanie Stewart

Jun. 18, 2019 JA1140

32. Comment Shelley Masters Jun. 17, 2019 JA1142 33. Ex Parte Kevin Mottus Sep. 15, 2020 JA1144 34. Comment Jennifer Page Jun. 18, 2019 JA1163 35. Comment Carol Spoelma Jun. 18, 2019 JA1165 36. Comment Nina Beety Jun. 4, 2019 JA1167 37. Comment Angela

Lyubarsky Jun. 18, 2019 JA1170

38. Comment Janet Tache Oct. 3, 2019 JA1172 39. Comment Shelley Masters Jun.18, 2019 JA1174 40. Comment Virginia

Cottone Jun. 4, 2019 JA1176


vi

41. Comment Kathleen Heller Oct 7, 2019 JA1178 42. Comment Warren

Woodward Jun.3, 2019 JA1180

43. Comment Debra R. Van Dusen

Oct.15, 2019 JA1182

44. Comment Virginia Cottone

Jun. 4, 2019 JA1184

45. Reply Comment Mary Beth Brangan

Jun.18, 2019 JA1186

46. Comment Matina Johnson Jun. 17, 2019 JA1191 47. Comment Angela Tsiang Jun. 18, 2019 JA1194 48. Reply Comment Mary Beth

Brangan Jun.18, 2019 JA1200

49. Comment Brigitte Otto Jun. 18, 2019 JA1205 50. Reply Comment Mark Wahl Jun. 5, 2019 JA1207 51. Comment Nancy Wallace Jun.17, 2019 JA1209 52. Reply Comment Mary Beth



Jun. 4, 2019 JA1216

54. Comment Melissa Corinne Senger

Jun.17, 2019 JA1218

55. Comment Virginia Farver Jun.3, 2019 JA1220 56. Comment Kathleen Heller Jun.17, 2019 JA1222 57. Comment James S.

Wazorick Jun.17, 2019 JA1224

58. Comment Chuck Hinz Jun.18, 2019 JA1226 59. Reply Comment Dan Kleiber Jun. 18, 2019 JA1228 60. Comment Janet Tache Oct. 3, 2019 JA1234 61. Comment Matina Johnson Jun. 17, 2019 JA1236 62. Comment Jonathan Mirin Jun. 18, 2019 JA1239 63. McKenzie Jennings Comment Susan Jennings,

McKenzie Oct.2, 2019 JA1241


vii

Jennings, Michael Jennings

64. Comment Shelley Masters Jun. 18, 2019 JA1243 65. Comment Debra R. Van

Dusen Oct. 15, 2019 JA1245

66. Comment Matina Johnson Jun.17, 2019 JA1247 67. Comment Angela Tsiang Jun. 18, 2019 JA1250 68. Comment Jonathan Mirin Jun. 18, 2019 JA1256 69. Comment Erica Elliot Jun.17, 2019 JA1258 70. Comment Cindy Sallis Jun. 18, 2019 JA1260

VOLUME 8

71. McKenzie Jennings Comment Susan Jennings, McKenzie Jennings, Michael Jennings

Oct.2, 2019 JA1262

72. Ex Parte Jodi Nelson Jun. 4, 2019 JA1264 73. Comment James L.

Yarbrough May 4, 2020 JA1266

74. Comment Matina Johnson Jun.17, 2019 JA1268 75. Comment Daniel

Kinderlehrer Jun. 5, 2019 JA1271

76. Comment Kelly Sutton Jun.17, 2019 JA1273 77. Ex Parte Jodi Nelson Jun. 4, 2019 JA1275 78. Comment James L.


79. Reply Comment Matina Johnson Jun.17, 2019 JA1279 80. Susan Jennings Comment Susan Jennings,


Oct 2, 2019 JA1282


viii

81. Comment Alexandra Ansell

Jun. 18, 2019 JA1284


Oct.2, 2019 JA1286

83. Comment Dr. Lora Chamberlain

Oct.7, 2019 JA1288

84. Comment Vicki Gold Oct.4, 2019 JA1290 85. Comment Cindy Ladig Jun.17, 2019 JA1292 86. Comment James L.


87. Comment Nina Beety Jun. 4, 2019 JA1296 88. Comment James S.

Wazorick Jun.17, 2019 JA1299

89. Comment Brenda Renschler

Jun.17, 2019 JA1301


Oct.2, 2019 JA1303

91. Comment Jennifer Page Jun.18, 2019 JA1305 92. Ex Parte Jodi Nelson Jun. 4, 2019 JA1307 93. Comment Nancy Hirsch Jun.17, 2019 JA1309 94. Comment Joseph T.

Carroll Jun. 19, 2019 JA1311

95. Comment Warren Woodward

Jun.3, 2019 JA1313

96. Comment Tarra Light Jun.17, 2019 JA1315 97. Comment Deborah

Chandler Jun. 18, 2019 JA1317

98. Reply Comment Matina Johnson Jun.17, 2019 JA1319


ix

99. Comment Angela Tsiang Jun.18, 2019 JA1322 100. Comment Jonathan Mirin Jun.18, 2019 JA1328 101. Comment Chuck Hinz Jun.18, 2019 JA1330 102. Comment Joseph T.

Carroll Jun.19, 2019 JA1332

103. Comment Stephanie Stewart

Jun. 18, 2019 JA1334

104. Comment Robin Oaks Jun.14, 2019 JA1336 105. Comment Sylvia Skefich Jun.17, 2019 JA1338 106. Comment Shelley Masters Jun. 18, 2019 JA1340 107. Susan Jennings Comment Susan Jennings,


Oct.2, 2019 JA1342

108. Mike Jennings Comment Susan Jennings, McKenzie Jennings, Michael Jennings

Oct.2, 2019 JA1344

109. Reply Comment Dan Kleiber Jun.18, 2019 JA1346 110. Reply Comment Catherine

Kleiber Oct.7, 2019 JA1352

111. Comment John Lumier-Wins

Jun.17, 2019 JA1364

112. Comment Brigitte Otto Jun.18, 2019 JA1366 113. Comment Brigitte Otto Jun.18, 2019 JA1368 114. Comment Nina Beety Jun.4, 2019 JA1370 115. Comment Nina Beety Jun.18, 2019 JA1373 116. Ex Parte Jodi Nelson Jun. 4, 2019 JA1379 117. Comment Jennifer Page Jun.18, 2019 JA1381 118. Comment Kathleen Heller Oct.7, 2019 JA1383 119. Comment Debra R. Van

Dusen Oct.15, 2019 JA1385


x

120. Comment Linda Kurtz Jun. 18, 2019 JA1387 121. Comment Jane Ferris Jun.17, 2019 JA1389 122. Comment Janet Tache Oct. 3, 2019 JA1391 123. Comment Carol Spoelma Jun.18, 2019 JA1393 124. Comment Alexandra

Ansell Jun.18, 2019 JA1395

125. Comment Tamara Schuppin

Oct.7, 2019 JA1397

126. Comment James S. Wazorick

Jun.17, 2019 JA1399

VOLUME 9

127. Comment Thomas Nichols, Robin Nichols

Jun.17, 2019 JA1401

128. Comment William R Duggan Jr, Charlotte M Duggan, William R Duggan III

Jun.18, 2019 JA1403

129. Comment Angela Lyubarsky

Jun.18, 2019 JA1405


Jun.17, 2019 JA1407

131. Comment Maureen Block Oct.7, 2019 JA1409 132. Comment Lise Sheehan Jun.18, 2019 JA1411 133. Comment Michele Hertz Jun.17, 2019 JA1413 134. Comment Dina Lopez Jun.18, 2019 JA1415 135. Comment Randall Tongg Jun.18, 2019 JA1417 136. Comment Kathy Brown Jun.18, 2019 JA1419 137. Comment Mary Karen

McClellan Jun.19, 2019 JA1421

138. Comment Ewa Wludecka, Marcin

Oct.1, 2019 JA1423


xi

Wludecki, Adrian Wludecki, Michal Wludecki

139. Comment Jennifer Breeze Jun.17, 2019 JA1425 140. Comment Cynthia

McCaffrey Jun.18, 2019 JA1427

141. Comment Raylyn Terrell Jun.17, 2019 JA1429 142. Comment Ajna Orion Jun.17, 2019 JA1431 143. Comment Rebeca Randle Jun.18, 2019 JA1433 144. Comment David Randle Jun.18, 2019 JA1435 145. Comment Bonnie

McMurry Jun.3, 2019 JA1437

146. Comment Virginia Farver Jun.3, 2019 JA1439 147. Comment James L.


148. Comment Brian Snodgrass, Tanja Snodgrass

Oct.4, 2019 JA1443

149. Comment Margaret J. Phillips

Oct.3, 2019 JA1445

150. Comment Linda Beck Jun.17, 2019 JA1447 151. Comment Nancy Hirsch Jun.17, 2019 JA1449 152. Comment Patty Overton Jun.18, 2019 JA1451 153. Comment Patricia Burke Jun.17, 2019 JA1453 154. Comment Daniel Schultz Jun.18, 2019 JA1455 155. Comment Donna Lyell Jun.17, 2019 JA1458 156. Comment Joanna Crump Jun.17, 2019 JA1460 157. Comment Brenda

Tenerelli Jun.18, 2019 JA1462

158. Comment Nina Anderson Jun.17, 2019 JA1464


xii

159. Comment Rheba Kelley Jun.17, 2019 JA1466 160. Comment Diane Van

Schoyck Jun.17, 2019 JA1468

161. Comment Tarra Light Jun.17, 2019 JA1470 162. Comment Victoria Knox Jun.18, 2019 JA1472 163. Comment Deborah

Chandler Jun.18, 2019 JA1474

164. Comment Olemara Peters Jun.18, 2019 JA1476 165. Comment Debora Cantel Jun.18, 2019 JA1478 166. Comment Nicolas Segaud Jun.18, 2019 JA1480 167. Comment Linda

Livingston Jun.18, 2019 JA1482

168. Comment Carol Sorenson Jun.17, 2019 JA1484 169. Comment Berry C.

Bartolillo Jun.18, 2019 JA1486

170. Comment Esther Le Sieur Oct.4, 2019 JA1488 171. Comment Jane Brewer Jun.18, 2019 JA1490 172. Comment Janet

Templeton-Heise

Jun.18, 2019 JA1492

173. Comment Cate Marino Jun.18, 2019 JA1494 174. Comment Mary Epiphan Jun.17, 2019 JA1496 175. Comment Beth Robinson Jun.18, 2019 JA1498 176. Comment Cindy Sallis Jun. 18, 2019 JA1500 177. Susan Jennings Comment Susan Jennings,


Oct. 2, 2019 JA1502


Jun. 17, 2019 JA1504

179. Comment Maureen Block Oct. 7, 2019 JA1506 180. Comment Robin Oaks Jun. 14, 2019 JA1508


xiii


Oct. 2, 2019 JA1510

182. Michael Jennings Comment Susan Jennings, McKenzie Jennings, Michael Jennings

Oct. 2, 2019 JA1512

183. Reply Comment Dan Kleiber Jun. 18, 2019 JA1514 184. Comment Annie Ruby Jun. 18, 2019 JA1520 185. Comment Tamara

Schuppin Oct. 7, 2019 JA1522


Jun. 17, 2019 JA1524


Jun. 17, 2019 JA1526


Jun. 18, 2019 JA1528


Jun. 18, 2019 JA1530

190. Comment Mary Knapp Jun. 18, 2019 JA1532 191. Comment Bonita

McComb Jun. 19, 2019 JA1534

192. Comment Susan Jennings Jun. 18, 2019 JA1536 193. Reply Comment Matina Johnson Jun. 17, 2019 JA1538 194. Ex Parte Kevin Mottus Sep. 15, 2020 JA1541 195. McKenzie Jennings Comment Susan Jennings,

McKenzie Oct. 2, 2019 JA1560


xiv

Jennings, Michael Jennings

196. Comment Matina Johnson Jun.17, 2019 JA1562 197. Comment Jonathan Mirin Jun. 18, 2019 JA1565 198. Comment Shelley Masters Jun. 18, 2019 JA1567 199. Ex Parte Jodi Nelson Jun. 4, 2019 JA1569

Part 1 -Tachover Declaration Exhibit 2: List of Objecting Persons Joining in CHD Comment


May 19, 2020 JA0089

VOLUME 10

200. Reply Mary Beth Brangan

Jun. 18, 2019 JA1571

201. Comment Robin Oaks Jun. 14, 2019 JA1576 202. Susan Jennings Comment Susan Jennings,


Oct. 2, 2019 JA1578

203. Michael Jennings Comment Susan Jennings, McKenzie Jennings, Michael Jennings

Oct. 2, 2019 JA1580

204. Comment Nina Beety Jun. 4, 2019 JA1582 205. Comment Nina Beety Jun. 18, 2019 JA1585 206. Comment Stephanie

Stewart Jun. 18, 2019 JA1591

207. Comment Jennifer Page Jun. 18, 2019 JA1593 208. Comment Carol Spoelma Jun. 18, 2019 JA1595 209. Comment Alexandra



xv


Jun. 17, 2019 JA1599


Jun. 18, 2019 JA1601


Jun. 17, 2019 JA1603

213. Comment Randall Tongg Jun. 18, 2019 JA1605 214. Comment Ajna Orion Jun. 17, 2019 JA1607 215. Comment Joseph T.


216. Comment Bonnie McMurry

Jun. 3, 2019 JA1611

217. Comment Virginia Farver Jun. 3, 2019 JA1613 218. Comment James L.


219. Comment Mary Knapp Jun. 18, 2019 JA1617 220. Comment Margaret J.

Phillips Oct. 3, 2019 JA1619

221. Comment Linda Beck Jun. 17, 2019 JA1621 222. Comment Nancy Hirsch Jun. 17, 2019 JA1623 223. Comment Patricia Burke Jun. 17, 2019 JA1625 224. Comment Deborah


225. Comment Olemara Peters Jun. 18, 2019 JA1629 226. Comment Carol Sorenson Jun. 17, 2019 JA1631 227. Comment Berry C.

Bartolillo Jun. 18, 2019 JA1633

228. Comment Esther Le Sieur Oct. 4, 2019 JA1635 229. Comment Deborah

Kopald Jun. 18, 2019 JA1637

230. Comment Stephanie Thomas

Jun. 18, 2019 JA1640

231. Comment John Frink Jun. 4, 2019 JA1642


xvi

232. Reply Comment Kimberly Modesitt

Jun. 10, 2019 JA1644


Jun. 17, 2019 JA1646

234. Reply Mark Wahl Jun. 5, 2019 JA1648 235. Comment Warren

Woodward Jun. 3, 2019 JA1650

236. Comment Jacquelyn Griffith

Jun. 18, 2019 JA1652

237. Comment Peter Morton, Anna Marie Morton

Jun. 6, 2019 JA1654

238. Comment Barbara Laurie Keith

Jun. 17, 2019 JA1656

239. Comment Dr. Lora Chamberlain

Oct. 4, 2019 JA1658

240. Comment Vicki Gold Oct. 4, 2019 JA1660 241. Comment Cindy Ladig Jun. 17, 2019 JA1662 242. Comment James L.


243. Comment Robin Oaks Jun. 14, 2019 JA1666 244. Reply Comment Matina Johnson Jun. 17, 2019 JA1668 245. McKenzie Jennings Comment Susan Jennings,


Oct. 2, 2019 JA1671

246. Susan Jennings Comment Susan Jennings, McKenzie Jennings, Michael Jennings

Oct. 2, 2019 JA1673

247. Reply Comment Catherine Kleiber

Oct. 7, 2019 JA1675

248. Comment Brigitte Otto Jun. 18, 2019 JA1687


xvii

249. Comment Brigitte Otto Jun. 18, 2019 JA1689 250. Ex Parte Jodi Nelson Jun. 4, 2019 JA1691 251. Comment Jennifer Page Jun. 18, 2019 JA1693 252. Comment Kathleen Heller Oct. 7, 2019 JA1695 253. Comment Debra R. Van

Dusen Oct. 15, 2019 JA1697

254. Comment Linda Kurtz Jun. 18, 2019 JA1699 255. Comment Janet Tache Oct. 3, 2019 JA1701 256. Comment Carol Spoelma Jun. 18, 2019 JA1703 257. Comment Alexandra


258. Comment Cinday Sallis Jun. 18, 2019 JA1707 259. Comment Tamara

Schuppin Oct. 7, 2019 JA1709


Jun. 17, 2019 JA1711


Jun. 18, 2019 JA1713


Jun. 17, 2019 JA1715

263. Comment Ewa Wludecka, Marcin Wludecki, Adrian Wludecki, Michal Wludecki

Oct. 1, 2019 JA1717

264. Comment Jennifer Breeze Jun. 17, 2019 JA1719 265. Comment Raylyn Terrell Jun. 17, 2019 JA1721 266. Comment Ajna Orion Jun. 17, 2019 JA1723


xviii


Oct. 4, 2019 JA1725

268. Comment Nancy Hirsch Jun. 17, 2019 JA1727 269. Comment Patty Overton Jun. 18, 2019 JA1729 270. Comment Patricia Burke Jun. 17, 2019 JA1731 271. Comment Daniel Schultz Jun. 18, 2019 JA1733 272. Comment Brenda

Tenerelli Jun. 18, 2019 JA1736

273. Comment Rheba Kelley Jun. 17, 2019 JA1738 VOLUME 11

274. Comment Diane Van Schoyck

Jun. 17, 2019 JA1740

275. Comment Tarra Light Jun. 17, 2019 JA1742 276. Comment Deborah


277. Comment Olemara Peters Jun. 18, 2019 JA1746 278. Comment Debora Cantel Jun. 18, 2019 JA1748 279. Comment Carol Sorenson Jun. 17, 2019 JA1750 280. Comment Esther Le Sieur Oct. 4, 2019 JA1752 281. Comment Mary Epiphan Jun. 17, 2019 JA1754 282. Comment Beth Robinson Jun. 18, 2019 JA1756 283. Comment Susan Jennings Jun. 18, 2019 JA1758 284. Comment Toby Stover Oct. 2, 2019 JA1760 285. Comment Virginia



Jun. 10, 2019 JA1764

287. Comment M. Tomko Jun. 17, 2019 JA1766 288. Comment Denise King,

Autumn King, Holly King

Jun. 18, 2019 JA1768


xix


Jun. 18, 2019 JA1770


Jun. 17, 2019 JA1775

291. Reply Mark Wahl Jun. 5, 2019 JA1777 292. Comment Michelle

Bradford Oct. 7, 2019 JA1779

293. Comment Peggy Nigro Oct. 8, 2019 JA1781 294. Comment Matt

Huntington Jun. 17, 2019 JA1783

295. Comment Sara Vandenbos Jun. 14, 2019 JA1785 296. Comment Karen Rogers Jun. 18, 2019 JA1787 297. Comment Jana Harris Jun. 17, 2019 JA1789 298. Comment Kimberly

Kohlmann Jun. 18, 2019 JA1791

299. Comment Jessica Holl Jun. 18, 2019 JA1793 300. Comment Erin Sintros Oct. 2, 2019 JA1795 301. Comment Deborah

Ladermann D.C.

Jun. 18, 2019 JA1797

302. Comment Stephen Dahl Oct. 2, 2019 JA1799 303. Comment Samantha

Tuinstra Jun. 17, 2019 JA1801

304. Comment Susan Straus Jun. 18, 2019 JA1803 305. Comment Peg Peterson Jun. 17, 2019 JA1805 306. Comment Miguel Trujillo Jun. 18, 2019 JA1807 307. Comment Anne Wilder Oct. 17, 2019 JA1809 308. Comment Lee Emerson,

Tesha Bananda Oct. 3, 2019 JA1811

309. Comment Mark McDonald

Jun. 18, 2019 JA1813

310. Comment Leo B Cashman Jun. 17, 2019 JA1815


xx

311. Comment Gayle Casas, Victor Casas, Dana Casas, Tyler Casas

Jun. 17, 2019 JA1817

312. Comment Clara Chapman Jun. 18, 2019 JA1819 313. Comment Debra Grayley,

Brian Grayley, Dorothy Cherney, Erwin Arnold

Jun. 19, 2019 JA1821

314. Comment Lori Littenberg, Stephen Littenberg

Jun. 18, 2019 JA1823

315. Comment Rebecca Liepke Jun. 1, 2020 JA1825 316. Comment Holly Johnson Jun. 4, 2019 JA1827 317. Comment Annmarie

Schroeder Jun. 17, 2019 JA1829

318. Comment Charmane Vaianisi

Jun. 17, 2019 JA1831

319. Comment Sam Parish Jun. 17, 2019 JA1833 320. Comment Stanley Banos Jun. 18, 2019 JA1835 321. Comment Eli Dumitru Jun. 18, 2019 JA1837 322. Comment Anna L. Marsh Jun. 18, 2019 JA1839 323. Comment Lynda Schartle Jun. 18, 2019 JA1841 324. Comment Stephanie

Falcone Jun. 18, 2019 JA1843

325. Comment Mary Nickell Jun. 18, 2019 JA1845 326. Comment Beverley Birks Jun. 18, 2019 JA1847 327. Comment Janice Harder

Golik Jun. 18, 2019 JA1849

328. Comment Mark Ahlheim Jun. 18, 2019 JA1851 329. Comment Jenni Johnson Jun. 18, 2019 JA1853 330. Comment Larissa Lyles Jun. 18, 2019 JA1855


xxi

331. Comment Whitney Walker

Jun. 18, 2019 JA1857

332. Comment M. Ann McMurdo

Jun. 18, 2019 JA1859

333. Comment Karen Gamal Jun. 18, 2019 JA1861 334. Comment Melissa Petrini Jun. 18, 2019 JA1863 335. Comment Lynette Yetter Jun. 18, 2019 JA1866 336. Comment Paula Boyer Jun. 18, 2019 JA1868 337. Comment Marissa Brand,

Colin Brand Oct. 3, 2019 JA1870

338. Comment Raymur Rachels

Oct. 7, 2019 JA1872


Jun. 6, 2019 JA1874

340. Comment Diane Royal Oct. 7, 2019 JA1876 341. Comment Barbara Laurie

Keith Jun. 17, 2019 JA1878

342. Comment L. Koenes Oct. 3, 2019 JA1880 343. Comment Ina Cottingham Oct. 7, 2019 JA1882 344. Comment Gloria Shen Oct. 3, 2019 JA1884 345. Comment Diana Corbett,

Michael Corbett Oct. 1, 2019 JA1886

346. Comment Ellen Marks Jun. 18, 2019 JA1888 347. Comment Lauren Galvin Oct. 8, 2019 JA1890 348. Comment Richard H

Conrad Oct. 7, 2019 JA1892

349. Comment Karen Beard Oct. 3, 2019 JA1894 350. Comment Jessie Bengoa Oct. 1, 2019 JA1896 351. Comment Steven M.

Murphy Oct. 1, 2019 JA1898

352. Comment Cynthia Hoffman

Oct. 3, 2019 JA1900


xxii

353. Comment Brittany Ardito Oct. 7, 2019 JA1902 354. Comment Jackie Wahlig Oct. 1, 2019 JA1904

VOLUME 12

355. Comment Christina Kleisath

Oct. 1, 2019 JA1906

356. Comment C.M. Hardt Oct. 1, 2019 JA1908 357. Comment Kristin

Moriarty Oct. 1, 2019 JA1910

358. Comment Neil Weiner Oct. 2, 2019 JA1912 359. Comment Justin

Uitenbroek Oct. 2, 2019 JA1914

360. Comment Nancy Fallaw Oct. 2, 2019 JA1916 361. Comment Julie Booras Oct. 2, 2019 JA1918 362. Comment Linda

Leibowitz Oct. 2, 2019 JA1920

363. Comment Kathleen Lynch Oct. 2, 2019 JA1922 364. Comment Charlene

Sansone Oct. 2, 2019 JA1924

365. Comment Sally Fisher Oct. 2, 2019 JA1926 366. Comment Lisa Laughlin Oct. 1, 2019 JA1928 367. Comment Christina

Rizzoni Oct. 1, 2019 JA1930

368. Comment Rhonda Arnold Oct. 1, 2019 JA1932 369. Comment Kristi

Cartwright Oct. 1, 2019 JA1934

370. Comment Andy Peri Oct. 1, 2019 JA1936 371. Comment Michelle

Kristoffersen Oct. 1, 2019 JA1938

372. Comment Regina Dimaggio

Oct. 1, 2019 JA1940

373. Comment India Hoeschen-Stein

Oct. 3, 2019 JA1942


xxiii

374. Comment Marlena Applebaum

Oct. 3, 2019 JA1944

375. Comment Kathleen Pierson

Oct. 3, 2019 JA1946

376. Comment Sandi Maurer Oct. 2, 2019 JA1948 377. Comment Roy Lamkin Oct. 2, 2019 JA1950 378. Comment Jennifer

Todhunter Oct. 2, 2019 JA1952

379. Comment Kimberly Uitenbroek

Oct. 2, 2019 JA1954

380. Comment Miriam Lindbeck

Oct. 2, 2019 JA1956

381. Comment Mary Rogers Oct. 2, 2019 JA1958 382. Comment Ann Ben Oct. 3, 2019 JA1960 383. Comment E P Lierman Oct. 3, 2019 JA1962 384. Comment Carissa Wages Oct. 3, 2019 JA1964 385. Comment Ari Cohen Oct. 3, 2019 JA1966 386. Comment Dave Molidor Oct. 3, 2019 JA1968 387. Comment Phoebe A.

McLeod Oct. 3, 2019 JA1970

388. Comment Joshua Stottlemyer, Amy Stottlemyer

Oct. 3, 2019 JA1972

389. Comment Tracey Roizman

Oct. 3, 2019 JA1974

390. Comment Pamela Whitman

Oct. 3, 2019 JA1976

391. Comment Amber Bryan Oct. 3, 2019 JA1978 392. Comment David Rutten Oct. 3, 2019 JA1980 393. Comment Kim Black,

Angelina Laubsch, Alan Laubsch,

Oct. 3, 2019 JA1982


xxiv

Bertrand Laubsch, Celine Laubsch

394. Comment Yvonne Aileen Oct. 3, 2019 JA1984 395. Comment Paula DP

London Oct. 3, 2019 JA1986

396. Comment Eva McCall Oct. 3, 2019 JA1988 397. Comment Mr. Robert W.

Toungate Oct. 3, 2019 JA1990

398. Comment Matthew London

Oct. 3, 2019 JA1992

399. Comment Kim Stribling Oct. 3, 2019 JA1994 400. Comment Susan Long,

John Long, Hanna Long, Sara Long, Trevor Barker, Jordan Sego, Hanna Sego, Rebeka Long, Jack Morgan

Oct. 3, 2019 JA1996

401. Comment Mary Thomas Oct. 4, 2019 JA1998 402. Comment James Wecker Oct. 4, 2019 JA2000 403. Comment James Laba Oct. 7, 2019 JA2002 404. Comment Karen Gadol Oct. 7, 2019 JA2004 405. Comment Sita Ryan Oct. 7, 2019 JA2006 406. Comment J.A. Blahnik Oct. 7, 2019 JA2008 407. Comment Gabriele Steiner Oct. 7, 2019 JA2010 408. Comment William S.

Bathgate Oct. 7, 2019 JA2012

409. Comment Mandy Gloyeske, Brad Gloyeske

Oct. 7, 2019 JA2014

410. Comment Paula Mooney Oct. 7, 2019 JA2016


xxv

411. Comment Calista Woodbridge

Oct. 7, 2019 JA2018

412. Comment Christy Poniatowski

Oct. 7, 2019 JA2020

413. Comment Jennifer Stahl Oct. 7, 2019 JA2022 414. Comment Lewis Elbinger Oct. 7, 2019 JA2024 415. Comment VD Patel Oct. 7, 2019 JA2026 416. Comment Carol Landry Oct. 7, 2019 JA2028 417. Comment Virginia Ann

Hicks Oct. 8, 2019 JA2030

418. Comment Kelly Metke Oct. 8, 2019 JA2032 419. Comment Susan Stewart Oct. 8, 2019 JA2034 420. Comment Jocelyn Horst Oct. 8, 2019 JA2036 421. Comment Bonnie

Loewenstein Oct. 3, 2019 JA2038

422. Comment Patrice Lynn Oct. 3, 2019 JA2040 423. Comment Janet

Stottlemyer Oct. 3, 2019 JA2042

424. Comment Linda Sue Kocsis, Keith James Kocsis

Oct. 3, 2019 JA2044

425. Comment Tom McCarey Oct. 3, 2019 JA2046 426. Comment Lisa Horn Oct. 3, 2019 JA2048 427. Comment Bonnie Menth Oct. 3, 2019 JA2050 428. Comment David Adams Oct. 3, 2019 JA2052 429. Comment Carl Estes Oct. 3, 2019 JA2054 430. Comment Nata Saper Oct. 3, 2019 JA2056 431. Comment Lawrence

Wallman Oct. 3, 2019 JA2058

432. Comment Jae Gruenke Oct. 4, 2019 JA2060 433. Comment Laura Webb Oct. 4, 2019 JA2062 434. Comment Andrea J.

Plamondon Oct. 4, 2019 JA2064


xxvi

435. Comment Alton Stearns, Juanita Strickland

Oct. 4, 2019 JA2066

436. Comment Olivia J. Schneider, Brett Hoyt

Oct. 4, 2019 JA2068

VOLUME 13

437. Comment M Faenger, J Faenger, V Faenger, A Faenger, S Shabanov, V Shabanov

Oct. 4, 2019 JA2070

438. Comment Jenna Nelson Oct. 4, 2019 JA2072 439. Comment Raina Stewart Oct. 4, 2019 JA2074 440. Comment Dianna

Bessette, Matt Olson

Oct. 4, 2019 JA2076

441. Comment Roberta Bolduc Oct. 4, 2019 JA2078 442. Comment Diane Harrison Oct. 4, 2019 JA2080 443. Comment Thomas Keen Oct. 4, 2019 JA2082 444. Comment Ann Zavala Oct. 4, 2019 JA2084 445. Comment Lisa Meserve Oct. 4, 2019 JA2086 446. Comment Randy and

Cindy Baker Dec.5, 2019 JA2088

447. Comment Diane Rodich Nov 5, 2019 JA2090 448. Comment Dana

Weintraub Nov 27, 2019 JA2092

449. Comment Steffani LaZier Nov 4, 2019 JA2094 450. Comment Claire Viadro Oct. 31, 2019 JA2096 451. Comment Joni Aarden,

Triangle Citizens for Safe Technology

Oct. 30, 2019 JA2098


xxvii

452. Comment Olivia Chasteen Oct. 7, 2019 JA2000 453. Comment Allison Jobke Oct. 7, 2019 JA2102 454. Comment Anca Sira Oct. 7, 2019 JA2104 455. Comment Adriana Di

Cecco Oct. 7, 2019 JA2106

456. Comment Kevin Norris, Lynda Norris, Doris Casey

Oct. 7, 2019 JA2108

457. Comment Michelle Grimestad

Oct. 7, 2019 JA2110

458. Comment Ralph Thomas Oct. 7, 2019 JA2112 459. Comment Kevin Metke Oct. 8, 2019 JA2114 460. Comment Marcel Longpre Jun. 18, 2019 JA2116 461. Comment Judy Caruso Jun. 18, 2019 JA2118 462. Comment Christine Heady Jun. 18, 2019 JA2120 463. Comment SC Jennings Jun. 18, 2019 JA2122 464. Comment Karen Palmer Jun. 18, 2019 JA2124 465. Comment Elizabeth Kroll Jun. 18, 2019 JA2126 466. Comment Elizabeth Bates Jun. 18, 2019 JA2128 467. Comment Kate Inserra Oct. 3, 2019 JA2130 468. Comment Susan B.

Samoriski, Ed.D

Jun. 18, 2019 JA2132

469. Comment Laurie Bloom Jun. 18, 2019 JA2134 470. Comment Nicole Lawson Oct. 7, 2019 JA2136 471. Comment Kathy Bates Jul. 26, 2019 JA2138 472. Comment KathyMcComm

on Jun. 18, 2019 JA2140

473. Comment Caren Richard Jun. 17, 2019 JA2142 474. Comment Stephanie

Zegers Jun. 21, 2019 JA2144

475. Comment Mike Anderson Oct. 3, 2019 JA2146


xxviii

476. Comment Jolene Anderson

Oct. 3, 2019 JA2148

477. Comment MaryJo Gallaway

Oct. 7, 2019 JA2150

478. Comment Tamara Jackson Oct. 3, 2019 JA2152 479. Comment Catherine Hunn Oct. 2, 2019 JA2154 480. Comment Joanne Halpin Jun. 21, 2019 JA2156 481. Comment Oscar Perez Jun. 20, 2019 JA2158 482. Comment Theresa Quiroz Jun. 20, 2019 JA2160 483. Comment Melinda


484. Comment D. Emmel Jun. 19, 2019 JA2164 485. Comment Kevin Vidrine Jun. 18, 2019 JA2166 486. Comment Victor Almeida Jun. 17, 2019 JA2168 487. Comment Jane

Rittenhouse Jun. 18, 2019 JA2170

488. Comment David John Smith Jr.

Oct. 2, 2019 JA2172

489. Comment Tessa Lachman Oct. 2, 2019 JA2174 490. Comment Nick Quinlan Jun. 18, 2019 JA2176 491. Comment Elaine Unger,

John Unger Jun. 18, 2019 JA2178

492. Comment Alexis Schroeder

Jun. 18, 2019 JA2180

493. Comment Larry Oppriecht Jun. 17, 2019 JA2182 494. Comment Lauren Farina Jun. 17, 2019 JA2184 495. Comment Nancy Kaiser Jun. 18, 2019 JA2186 496. Comment Frank Kaanoi Jun. 18, 2019 JA2188 497. Comment Linda Kean Jun. 18, 2019 JA2180 498. Comment Kelley Barnes-

Valdes Jun. 18, 2019 JA2192

499. Comment Christopher Payne

Jun. 18, 2019 JA2194


xxix

500. Comment Theresa, Nielsen

Jun. 19, 2019 JA2196

501. Comment Katelyn VonMyhr

Oct. 1, 2019 JA2199

502. Comment Molly Brown Jun. 17, 2019 JA2201 503. Comment Allison Bagg Jun. 17, 2019 JA2203 504. Comment William

Bensussen Jun. 17, 2019 JA2205

505. Comment Deana Eichenstein

Jun. 17, 2019 JA2207

506. Comment John C. Pronchik

Jun. 18, 2019 JA2209

507. Comment Lauren Wuthrich

Jun. 18, 2019 JA2211

508. Comment Jim Turner Jun. 18, 2019 JA2213 509. Comment Brandi Graham Jun. 18, 2019 JA2215 510. Comment Cindy Sallis Jun. 18, 2019 JA2217 511. Comment Peg Peterson Jun. 17, 2019 JA2219 512. Comment James L.


513. Comment Nina Beety Jun. 4, 2019 JA2223 514. Reply Mark Wahl Jun. 5, 2019 JA2226 515. Comment Elizabeth

Kelley Jun. 17, 2019 JA2228

516. Comment Citizens for Health, Kate Kheel

Jun. 18, 2019 JA2231

VOLUME 14

517. Comment Sylvia Skefich Jun. 17, 2019 JA2235 518. McKenzie Jennings Comment Susan Jennings,


Oct.. 2, 2019 JA2237


xxx


Oct. 2, 2019 JA2239

520. Reply Comment Catherine Kleiber

Oct. 7, 2019 JA2241

521. Comment John Lumier-Wins

Jun. 17, 2019 JA2253

522. Comment Brigitte Otto Jun. 18, 2019 JA2255 523. Comment Brigitte Otto Jun. 18, 2019 JA2257 524. Comment Nina Beety Jun. 18, 2019 JA2249 525. Ex Parte Jodi Nelson Jun. 4, 2019 JA2265 526. Comment Stephanie

Stewart Jun. 18, 2019 JA2267

527. Comment Jennifer Page Jun. 18, 2019 JA2269 528. Comment Janet Tache Oct. 3, 2019 JA2271 529. Comment James S.

Wazorick Jun. 17, 2019 JA2273


Jun. 17, 2019 JA2275


Oct. 1, 2019 JA2277

532. Comment Jennifer Breeze Jun. 17, 2019 JA2279 533. Comment Raylyn Terrell Jun. 17, 2019 JA2281 534. Comment Ajna Orion Jun. 17, 2019 JA2283 535. Comment Brian

Snodgrass, Tanja Snodgrass

Oct. 4, 2019 JA2285


xxxi

536. Comment Linda Beck Jun. 17, 2019 JA2287 537. Comment Nancy Hirsch Jun. 17, 2019 JA2289 538. Comment Patricia Burke Jun. 17, 2019 JA2291 539. Comment Brenda

Tenerelli Jun. 18, 2019 JA2293

540. Comment Diane Van Schoyck

Jun. 17, 2019 JA2295

541. Comment Tarra Light Jun. 17, 2019 JA2297 542. Comment Esther Le Sieur Oct. 4, 2019 JA2299 543. Comment Mary Epiphan Jun. 17, 2019 JA2301 544. Comment C. Zehfus Oct. 2, 2019 JA2303 545. Comment Toby Stover Oct. 2, 2019 JA2306 546. Comment Virginia


547. Comment John Frink Jun. 4, 2019 JA2310 548. Reply Comment Kimberly

Modesitt Jun. 10, 2019 JA2312


Jun. 18, 2019 JA2314

550. Comment Lori Vanderhider

Oct. 1, 2019 JA2319

551. Comment Michelle Bradford

Oct. 7, 2019 JA2321

552. Comment Sara Vandenbos Jun. 14, 2019 JA2323 553. Comment Erin Sintros Oct. 2, 2019 JA2325 554. Comment Stephen Dahl Oct. 2, 2019 JA2327 555. Comment Samantha

Tuinstra Jun. 17, 2019 JA2329

556. Comment Susan Straus Jun. 18, 2019 JA2331 557. Comment Peg Peterson Jun. 17, 2019 JA2333 558. Comment Miguel Trujillo Jun. 18, 2019 JA2335 559. Comment Elise Godown Jun. 18, 2019 JA2337


xxxii

560. Comment Frederica Graham

Jun. 18, 2019 JA2339

561. Comment Marilyn Wood Jun. 18, 2019 JA2341 562. Comment Dale A.

Benjamin Jun. 19, 2019 JA2343

563. Comment Jeannette Hassberg

Jun. 3, 2020 JA2345

564. Comment Lee Emerson, Tesha Bananda

Oct. 3, 2019 JA2347

565. Comment Mark McDonald

Jun. 18, 2019 JA2349

566. Comment Kelly Marcotulli

Jun. 17, 2019 JA2351

567. Comment Peggy Williams Jun. 17, 2019 JA2353 568. Comment Gayle Casas,

Victor Casas, Dana Casas, Tyler Casas

Jun. 17, 2019 JA2355

569. Comment Debra Grayley, Brian Grayley, Dorothy Cherney, Erwin Arnold

Jun. 19, 2019 JA2357

570. Comment Rebecca Liepke Jun. 1, 2020 JA2359 571. Comment Holly Johnson Jun. 4, 2019 JA2361 572. Comment Ron Ward Jun. 5, 2019 JA2363 573. Comment Sheila Smith-

Ramirez Jun. 17, 2019 JA2365


Jun. 17, 2019 JA2367

575. Comment Sam Parish Jun. 17, 2019 JA2369 576. Comment Richard Yount Jun. 18, 2019 JA2371 577. Comment Anna L. Marsh Jun. 18, 2019 JA2373 578. Comment Lynda Schartle Jun. 18, 2019 JA2375


xxxiii

579. Comment Deborah, Tennant

Jun. 18, 2019 JA2377

580. Comment Denise Allen, Robert Allen

Jun. 18, 2019 JA2379

581. Comment Stephanie Falcone

Jun. 18, 2019 JA2381

582. Comment Mary Nickell Jun. 18, 2019 JA2383 583. Comment Beverley Birks Jun. 18, 2019 JA2385 584. Comment Janice Harder

Golik Jun. 18, 2019 JA2387

585. Comment Mark Ahlheim Jun. 18, 2019 JA2389 586. Comment Whitney

Walker Jun. 18, 2019 JA2401

587. Comment Erin Blanc Jun. 18, 2019 JA2393 588. Comment Lynette Yetter Jun. 18, 2019 JA2395 589. Comment Michelle

Rowton Jun. 19, 2019 JA2397

590. Comment Lynda Smith, Thomas Cowan, M.D.

Oct. 3, 2019 JA2399

VOLUME 15

591. Comment Cary Terrall May 22, 2020 JA2401 592. Comment Raymur

Rachels Oct. 7, 2019 JA2403


Jun. 6, 2019 JA2405


Keith Jun. 17, 2019 JA2409

596. Comment L. Koenes Oct. 3, 2019 JA2411 597. Comment Ina Cottingham Oct. 7, 2019 JA2413 598. Comment Gloria Shen Oct. 3, 2019 JA2415


xxxiv

599. Comment Ellen Marks Jun. 18, 2019 JA2417 600. Comment Lauren Galvin Oct. 8, 2019 JA2419 601. Comment Richard H





Oct. 3, 2019 JA2429

606. Comment Brittany Ardito Oct. 7, 2019 JA2431 607. Comment Jackie Wahlig Oct. 1, 2019 JA2433 608. Comment Christina

Kleisath Oct. 1, 2019 JA2435











621. Comment Rhonda Arnold Oct. 1, 2019 JA2461


xxxv

622. Comment Kristi Cartwright

Oct. 1, 2019 JA2463




Oct. 1, 2019 JA2469


Oct. 3, 2019 JA2471


Oct. 3, 2019 JA2473


Oct. 3, 2019 JA2475

629. Comment Sandi Mauerer Oct. 2, 2019 JA2477 630. Comment Roy Lamkin Oct. 2, 2019 JA2479 631. Comment Jennifer



Oct. 2, 2019 JA2483


Oct. 2, 2019 JA2485




Oct. 3, 2019 JA2501


xxxvi


Oct. 3, 2019 JA2503


Oct. 3, 2019 JA2505


Angelina Laubsch, Alan Laubsch, Bertrand Laubsch, Celine Laubsch

Oct. 3, 2019 JA2511






Oct. 3, 2019 JA2521



Oct. 3, 2019 JA2525

654. Comment Mary Thomas Oct. 4, 2019 JA2527 655. Comment James Wecker Oct. 4, 2019 JA2529 656. Comment James Laba Oct. 7, 2019 JA2531 657. Comment Karen Gadol Oct. 7, 2019 JA2533


xxxvii

658. Comment Sita Ryan Oct. 7, 2019 JA2535 659. Comment J.A. Blahnik Oct. 7, 2019 JA2537 660. Comment Gabriele Steiner Oct. 7, 2019 JA2539 661. Comment William S.

Bathgate Oct.. 7, 2019 JA2541


Oct. 7, 2019 JA2543

663. Comment Paula Mooney Oct. 7, 2019 JA2545 664. Comment Calista

Woodbridge Oct. 7, 2019 JA2547


Oct. 7, 2019 JA2549



VOLUME 16






Oct. 3, 2019 JA2573

678. Comment Tom McCarey Oct. 3, 2019 JA2575 679. Comment Lisa Horn Oct. 3, 2019 JA2577


xxxviii

680. Comment Bonnie Menth Oct. 3, 2019 JA2579 681. Comment David Adams Oct. 3, 2019 JA2581 682. Comment Carl Estes Oct. 3, 2019 JA2583 683. Comment Nata Saper Oct. 3, 2019 JA2585 684. Comment Lawrence


685. Comment Jae Gruenke Oct. 4, 2019 JA2589 686. Comment Laura Webb Oct. 4, 2019 JA2591 687. Comment Andrea J



Oct. 4, 2019 JA2595

689. Comment Olivia J Schneider, Brett Hoyt

Oct. 4, 2019 JA2597


Oct. 4, 2019 JA2599



Oct. 4, 2019 JA2605

694. Comment Roberta Bolduc Oct. 4, 2019 JA2607 695. Comment Diane Harrison Oct. 4, 2019 JA2609 696. Comment Thomas Keen Oct. 4, 2019 JA2611 697. Comment Ann Zavala Oct. 4, 2019 JA2613 698. Comment Lisa Meserve Oct. 4, 2019 JA2615 699. Comment Randy and



xxxix





Oct. 30, 2019 JA2627




Oct. 7, 2019 JA2637


Oct. 7, 2019 JA2639

711. Comment Ralph Thomas Oct. 7, 2019 JA2641 712. Comment Kevin Metke Oct. 8, 2019 JA2643 713. Comment Christine Heady Jun. 18, 2019 JA2645 714. Comment Karen Palmer Jun. 18, 2019 JA2647 715. Comment Kate Inserra Oct. 3, 2019 JA2649 716. Comment Laurie Bloom Jun. 18, 2019 JA2651 717. Comment Nicole Lawson Oct. 7, 2019 JA2653 718. Comment Kathy Bates Jul 26, 2019 JA2655 719. Comment Kathy

McCommon Jun. 18, 2019 JA2657




xl

722. Comment Mike Anderson Oct. 3, 2019 JA2663 723. Comment Jolene

Anderson Oct. 3, 2019 JA2665


Oct. 7, 2019 JA2667



731. Comment D. Emmel Jun. 19, 2019 JA2681 732. Comment Kevin Vidrine Jun. 18, 2019 JA2683 733. Comment Victor Almeida Jun. 17, 2019 JA2685 734. Comment Jane



Oct. 2, 2019 JA2689

736. Comment Tessa Lachman Oct. 2, 2019 JA2691 737. Comment Nick Quinlan Jun. 18, 2019 JA2693 738. Comment Elaine Unger,

John Unger Jun. 18, 2019 JA2695


Jun. 18, 2019 JA2697

740. Comment Larry Oppriecht Jun. 17, 2019 JA2699 741. Comment Heidi Junger Jun. 18, 2019 JA2701 742. Comment Nancy Kaiser Jun. 18, 2019 JA2703 743. Comment Frank Kaanoi Jun. 18, 2019 JA2705 744. Comment Linda Kean Jun. 18, 2019 JA2707 745. Comment Christopher

Payne Jun. 18, 2019 JA2709


xli

746. Comment Katelyn VonMyhr

Oct. 1, 2019 JA2711

747. Comment Bruce J. Miller Oct. 1, 2019 JA2713 748. Comment Sue Newton,

Jim Newton May 22, 2020 JA2715

749. Comment Molly Brown Jun. 17, 2019 JA2717 750. Comment Lauren

Wuthrich Jun. 18, 2019 JA2719

751. Comment Jim Turner Jun. 18, 2019 JA2721 VOLUME 17

752. Comment Brandi Graham Jun. 18, 2019 JA2723 753. Ex Parte Kevin Mottus Sep 15, 2020 JA2725 754. Comment James L.



Jun.17, 2019 JA2746


Jun.17, 2019 JA2748

757. Comment Nina Beety Jun.4, 2019 JA2750 758. Comment Warren


759. Comment Robin Oaks Jun.14, 2019 JA2755 760. Comment Nina Beety Jun.18, 2019 JA2757 761. Ex Parte Jodi Nelson Jun.4, 2019 JA2763 762. Comment Jennifer Page Jun.18, 2019 JA2765 763. Comment Jane Ferris Jun.17, 2019 JA2767 764. Comment Janet Tache Oct.3, 2019 JA2769 765. Comment Angela

Lyubarsky Jun.18, 2019 JA2771


Jun.17, 2019 JA2773

767. Comment Ewa Wludecka, Marcin

Oct.1, 2019 JA2775


xlii

Wludecki, Adrian Wludecki, Michal Wludecki

768. Comment Ajna Orion Jun.17, 2019 JA2777 769. Comment Joseph T

Carroll Jun.19, 2019 JA2779


Jun.3, 2019 JA2781

771. Comment Virginia Farver Jun.3, 2019 JA2783 772. Comment Linda Beck Jun.17, 2019 JA2785 773. Comment Nancy Hirsch Jun.17, 2019 JA2787 774. Comment Patricia Burke Jun.17, 2019 JA2789 775. Comment Diane Van


776. Comment Tarra Light Jun.17, 2019 JA2793 777. Comment Deborah


778. Comment Olemara Peters Jun.18, 2019 JA2797 779. Comment Jonathan Mirin Jun.18, 2019 JA2799 780. Comment Berry C.


781. Comment Mary Epiphan Jun.17, 2019 JA2803 782. Comment C. Zehfus Oct.2, 2019 JA2805 783. Comment Stephanie

Thomas Jun.18, 2019 JA2808


Jun.10, 2019 JA2810

785. Reply Mark Wahl Jun.5, 2019 JA2812 786. Comment Susan Straus Jun.18, 2019 JA2814 787. Comment Dale A.

Benjamin Jun.19, 2019 JA2816


xliii


Oct.3, 2019 JA2818

789. Comment Cathy Cooke Jun.14, 2019 JA2820 790. Comment J. Adamo Jun.17, 2019 JA2822 791. Comment Alyssa L.

Barnes Jun.17, 2019 JA2824

792. Comment Dr. and Mrs. Michael Pavlov

Jun.17, 2019 JA2826

793. Comment Jack Rossi Jun.17, 2019 JA2828 794. Comment Gayle Casas,


Jun.17, 2019 JA2830

795. Comment Cynthia Price Jun.17, 2019 JA2832 796. Comment Emily Lanxner Jun.17, 2019 JA2834 797. Comment Lori Littenberg,

Stephen Littenberg

Jun.18, 2019 JA2836

798. Comment Sheilajean Whitefield

Jun.18, 2019 JA2838

799. Comment Laura Woodruff Jun.19, 2019 JA2840 800. Comment Rebecca Liepke Jun.1, 2020 JA2842 801. Comment Stephanie

Austin Jun.17, 2019 JA2844

802. Comment Cynthia Price Jun.17, 2019 JA2846 803. Comment Sam Parish Jun.17, 2019 JA2848 804. Comment Siochai

O’Connor Jun.18, 2019 JA2850

805. Comment Eli Dumitru Jun.18, 2019 JA2852 806. Comment Jennifer Aerts Jun.18, 2019 JA2854 807. Comment Michelle

Khatana Jun.18, 2019 JA2856

808. Comment Janice Harder Golick

Jun.18, 2019 JA2858


xliv


Jun.18, 2019 JA2860

810. Comment Michelle Rowton

Jun.19, 2019 JA2862


Oct.7, 2019 JA2864


Jun.6, 2019 JA2866


Jun.17, 2019 JA2868

814. Comment Lauren Galvin Oct.8, 2019 JA2870 815. Comment Kathleen

Pierson Oct.3, 2019 JA2872

816. Comment S.C. Jennings Jun.18, 2019 JA2874 817. Comment Keely Barnett Jun.18, 2019 JA2876 818. Comment Tania Teschke Jun.18, 2019 JA2878 819. Comment Christopher

Payne Jun.18, 2019 JA2880


Jun.18, 2019 JA2882

821. Comment Sylvia Skefich Jun.17, 2019 JA2884 822. Comment Diane Royal Oct.7, 2019 JA2886 823. Ex Parte Jodi Nelson Jun.4, 2019 JA2888 824. Comment Deborah


825. Comment Nancy Hirsch Jun.17, 2019 JA2892 826. Comment Warren


827. Comment Joseph T Carroll

Jun.19, 2019 JA2896

VOLUME 18

828. Ex Parte Kevin Mottus Sep 15, 2020 JA2898


xlv

829. Comment Robin Oaks Jun.14, 2019 JA2917 830. Comment Melissa

Corinne Senger Jun.17, 2019 JA2919


Jun.3, 2019 JA2921

832. Comment Virginia Farver Jun.3, 2019 JA2923 833. Comment Linda Beck Jun.17, 2019 JA2925 834. Comment Patricia Burke Jun.17, 2019 JA2927 835. Comment Tarra Light Jun.17, 2019 JA2929 836. Comment Olemara Peters Jun.18, 2019 JA2931 837. Comment Berry C.



Jun.17, 2019 JA2935

839. Comment Sam Parish Jun.17, 2019 JA2937 840. Comment Sylvia Skefich Jun.17, 2019 JA2939 841. Comment Stephanie


842. Comment James L. Yarbrough

May 4, 2020 JA2943

843. Ex Parte Kevin Mottus Sep 15, 2020 JA2945 844. Comment Brenda

Renschler Jun.17, 2019 JA2964


Jun.17, 2019 JA2966

846. Comment Robin Oaks Jun.14, 2019 JA2968 847. Comment Citizens for

Health, Kate Kheel

Jun.18, 2019 JA2970

848. Comment Nina Beety Jun.4, 2019 JA2974 849. Comment Nina Beety Jun.18, 2019 JA2977 850. Comment Janet Tache Oct. 3, 2019 JA2983


xlvi


Oct.1, 2019 JA2985

852. Comment Raylyn Terrell Jun.17, 2019 JA2987 853. Comment Ajna Orion Jun.17, 2019 JA2989 854. Comment Diane Van


855. Comment Tarra Light Jun.17, 2019 JA2993 856. Comment Mary Epiphan Jun.17, 2019 JA2995 857. Comment C. Zehfus Oct.2, 2019 JA2997 858. Comment Stephanie



Jun.4, 2019 JA3002

860. Comment John Frink Jun.4, 2019 JA3004 861. Reply Comment Kimberly

Modesitt Jun.10, 2019 JA3006

862. Comment Elaine Unger Jun.17, 2019 JA3008 863. Reply Mary Beth


864. Reply Mark Wahl Jun.5, 2019 JA3015 865. Comment Victoria Sievers Jun.4, 2019 JA3017 866. Comment Phoebe Sorgen Jun.4, 2019 JA3019 867. Comment Samantha

Tuinstra Jun.17, 2019 JA3021

868. Comment Mayara Carneiro

Jun.17, 2019 JA3023

869. Comment Yumi Wong Jun.17, 2019 JA3025 870. Comment Cathy Izzo Jun.18, 2019 JA3027 871. Comment Miguel Trujillo Jun.18, 2019 JA3029


xlvii

872. Comment Elise Godown Jun.18, 2019 JA3031 873. Comment Frederica

Graham Jun.18, 2019 JA3033

874. Comment J. Copp Jun.18, 2019 JA3035 875. Comment Marilyn Wood Jun.18, 2019 JA3037 876. Comment Dale A.

Benjamin Jun.19, 2019 JA3039

877. Comment Anne Wilder Oct.17, 2019 JA3041 878. Comment Gayle Casas,


Jun.17, 2019 JA3043


Jun.18, 2019 JA3045

880. Comment Lindsa Vallee Jun.4, 2019 JA3047 881. Comment Nancy Wallace Jun.17, 2019 JA3049 882. Comment Annmarie

Schroeder Jun.17, 2019 JA3051

883. Comment Sheila Smith-Ramirez

Jun.17, 2019 JA3053

884. Comment Michele Lance Jun.17, 2019 JA3055 885. Comment Siochai

O’Connor Jun.18, 2019 JA3057

886. Comment Eli Dumitru Jun.18, 2019 JA3059 887. Comment Jennifer Aerts Jun.18, 2019 JA3061 888. Comment Mark Ahlheim Jun.18, 2019 JA3063 889. Comment John Simonsen Jun.18, 2019 JA3065 890. Comment Whitney

Walker Jun.18, 2019 JA3067

891. Comment Paula Boyer Jun.18, 2019 JA3069 892. Comment Michelle

Rowton Jun.19, 2019 JA3071


xlviii

893. Comment David Morrow, Amanda Morrow

Oct.1, 2019 JA3073

VOLUME 19

894. Comment Lynda Smith Thomas Cowan, M.D.

Oct.3, 2019 JA3075


Oct.7, 2019 JA3077


Jun.6, 2019 JA3079

897. Comment Diane Royal Oct.7, 2019 JA3081 898. Comment Barbara Laurie

Keith Jun.17, 2019 JA3083

899. Comment Lauren Galvin Jun.18, 2019 JA3085 900. Comment Richard H

Conrad Oct.7, 2019 JA3087

901. Comment Susan B. Samoriski, Ed.D,

Jun.18, 2019 JA3089

902. Comment Susan Waterman

Jun.18, 2019 JA3091

903. Comment Oscar Perez Jun.20, 2019 JA3093 904. Comment Kevin Vidrine Jun.18, 2019 JA3095 905. Comment Victor Almeida Jun.17, 2019 KA3097 906. Comment Jane

Rittenhouse Jun.18, 2019 JA3099


Jun.18, 2019 JA3101


Jun.18, 2019 JA3103

909. Comment Bruce J. Miller Oct.1, 2019 JA3105


xlix


Jun.18, 2019 JA3107

911. Ex Parte United States Conference of Mayors et al

May 21, 2019 JA3109

912. Reply Comment City and County of San Francisco

Jun.17, 2019 JA3111

913. Reply Comment Oklahoma City et al

Jun.17, 2019 JA3123

914. Comment League of Minnesota Cities

Jun.3, 2019 JA3138

915. Reply Comment Washington Association of Telecommunications Officers and Advisors (WATOA)

Jun.12, 2019 JA3144

916. Comment City of Costa Mesa, California

Jun.3, 2019 JA3146

917. Comment Town of North Hempstead, New York

Jun.17, 2019 JA3149

918. Comment National Multifamily Housing Council et al

Jun.3, 2019 JA3151

919. Comment National League of Cities et al

Jun.3, 2019 JA3221

920. Ex Parte Kevin Mottus Sep 15, 2020 JA3230 921. Comment Elizabeth


922. Comment Robin Oaks Jun. 14, 2019 JA3252


l


Oct. 2, 2019 JA3254

924. Reply Comment Dan Kleiber Jun. 18, 2019 JA3256 925. Reply Comment Catherine

Kleiber Oct. 7, 2019 JA3262

926. Comment Nina Beety Jun. 4, 2019 JA3274 927. Comment Nina Beety Jun. 18, 2019 JA3277

VOLUME 20

928. Ex Parte Jodi Nelson Jun. 4, 2019 JA3283 929. Comment Debra R. Van

Dusen Oct. 15, 2019 JA3285

930. Comment Chuck Hinz Jun. 18, 2019 JA3287 931. Comment Janet Tache Oct. 3, 2019 JA3289 932. Comment Angela Tsiang Jun. 18, 2019 JA3291 933. Comment Melissa

Corinne Senger Jun. 17, 2019 JA3297

934. Comment Lise Sheehan Jun. 18, 2019 JA3299 935. Comment Jennifer Breeze Jun. 17, 2019 JA3301 936. Comment Ajna Orion Jun. 17, 2019 JA3303 937. Comment Bonnie

McMurry Jun. 3, 2019 JA3305

938. Comment Virginia Farver Jun. 3, 2019 JA3307 939. Comment James L.



Oct. 4, 2019 JA3311

941. Comment Nancy Hirsch Jun. 17, 2019 JA3313 942. Comment Deborah



li

943. Comment Olemara Peters Jun. 18, 2019 JA3317 944. Comment Esther Le Sieur Oct. 4, 2019 JA3319 945. Comment Mary Epiphan Jun. 17, 2019 JA3321 946. Comment Toby Stover Oct. 3, 2019 JA3323 947. Comment Dr. Lora

Chamberlain Oct. 7, 2019 JA3325

948. Comment Stephanie Thomas

Jun. 18, 2019 JA3327


Jun. 4, 2019 JA3329

950. Comment John Frink Jun. 4, 2019 JA3331 951. Kirstin Beatty,

Last Tree Laws Director

May 28, 2019 JA3333


Jun. 10, 2019 JA3335

953. Comment Denise King, Autumn King,Holly King

Jun. 18, 2019 JA3337

954. Comment Elaine Unger Jun. 17, 2019 JA3339 955. Reply Mary Beth

Brangan Jun. 18, 2019 JA3343


Jun. 17, 2019 JA3348

957. Reply Mark Wahl Jun. 5, 2019 JA3350 958. Comment Lori

Vanderhider Oct. 1, 2019 JA3352


Oct. 7, 2019 JA3354

960. Comment Geoffrey Shuey Jun. 17, 2019 JA3356 961. Comment Maxina Ventura Jun. 17, 2019 JA3358 962. Comment Matt



lii

963. Comment Sara Vandenbos Jun. 14, 2019 JA3362 964. Comment Victoria Sievers Jun. 4, 2019 JA3364 965. Comment Phoebe Sorgen Jun. 4, 2019 JA3366 966. Comment Erin Sintros Oct. 2, 2019 JA3368 967. Comment Stephen Dahl Oct. 2, 2019 JA3370 968. Comment Warren


969. Comment Dale A. Benjamin

Jun. 19, 2019 JA3374

970. Comment Jeannette Hassberg

Jun. 3, 2020 JA3376

971. Comment J. Adamo Jun. 17, 2019 JA3378 972. Comment Leo B Cashman Jun. 17, 2019 JA3380 973. Comment S.C. Jennings Jun. 18, 2019 JA3382 974. Comment Rebecca Liepke Jun. 1, 2020 JA3384 975. Comment Marilynne

Martin Jun. 4, 2020 JA3386

976. Comment John F Cowan Jun. 17, 2019 JA3388 977. Comment Nancy Wallace Jun. 17, 2019 JA3390 978. Comment Lucy Yang Jun. 17, 2019 JA3392 979. Comment Cynthia Price Jun. 17, 2019 JA3394 980. Comment Nancy L.

Wagner Jun. 17, 2019 JA3396


Jun. 17, 2019 JA3398

982. Comment John Crewdson Jun. 18, 2019 JA3400 983. Comment Meg Oberreuter Jun. 17, 2019 JA3402 984. Comment Sam Parish Jun. 17, 2019 JA3404 985. Comment Catherine Fish Jun. 18, 2019 JA3406 986. Comment Eli Dumitru Jun. 18, 2019 JA3408 987. Comment Jennifer Sohns Jun. 18, 2019 JA3410


liii


Jun. 18, 2019 JA3412

989. Comment Marylin Olds Jun. 18, 2019 JA3414 990. Comment Lucina Melissa

Lohse Jun. 18, 2019 JA3416


Jun. 18, 2019 JA3418

992. Comment Melissa Petrini Jun. 18, 2019 JA3420 993. Comment Anne Carpenter Jun. 18, 2019 JA3423 994. Comment Cynthia Ray Jun. 19, 2019 JA3425 995. Comment Adam Miller Oct. 7, 2019 JA3427 996. Comment Douglas

Matson Jun. 2, 2019 JA3429

997. Comment Gordon Bastian Jun. 2, 2019 JA3431 998. Comment Cary Terrall May 22, 2020 JA3433 999. Comment Raymur



Jun. 6, 2019 JA3437


Keith Jun. 17, 2019 JA3441

1003. Comment Gloria Shen Oct. 3, 2019 JA3443 1004. Comment Diana Corbett,


1005. Comment Ellen Marks Jun. 18, 2019 JA3447 1006. Comment Winifred

Thomas Oct. 3, 2019 JA3449

1007. Comment Richard H Conrad

Oct. 7, 2019 JA3451

VOLUME 21

1008. Comment Karen Beard Oct. 7, 2019 JA3453


liv

1009. Comment Jessie Bengoa Oct. 1, 2019 JA3455 1010. Comment Steven M.



Oct. 3, 2019 JA3459


















lv


Oct. 1, 2019 JA3499


Oct. 3, 2019 JA3501


Oct. 3, 2019 JA3503


Oct. 3, 2019 JA3505

1035. Comment Sandi Mauerer Oct.. 2, 2019 JA3507 1036. Comment Roy Lamkin Oct. 2, 2019 JA3509 1037. Comment Jennifer



Oct. 2, 2019 JA3513


Oct. 2, 2019 JA3515




Oct. 3, 2019 JA3531


Oct. 2, 2019 JA3533


Oct. 3, 2019 JA3535

1050. Comment Amber Bryan Oct. 3, 2019 JA3537 1051. Comment David Rutten Oct. 3, 2019 JA3539


lvi

1052. Comment Kim Black, Angelina Laubsch, Alan Laubsch, Bertrand Laubsch, Celine Laubsch

Oct. 3, 2019 JA3541






Oct. 3, 2019 JA3551



Oct. 3, 2019 JA3555

1060. Comment Mary Thomas Oct. 4, 2019 JA3557 1061. Comment James Wecker Oct. 4, 2019 JA3559 1062. Comment James Laba Oct. 7, 2019 JA3561 1063. Comment Karen Gadol Oct. 7, 2019 JA3563 1064. Comment Sita Ryan Oct. 7, 2019 JA3565 1065. Comment J.A. Blahnik Oct. 7, 2019 JA3567 1066. Comment Gabriele Steiner Oct. 7, 2019 JA3569 1067. Comment William S



lvii


Oct. 7, 2019 JA3573




Oct. 7, 2019 JA3579

1072. Comment Jennifer Stahl Oct. 7, 2019 JA3581 1073. Comment Lewis Elbinger Oct. 7, 2019 JA3583 1074. Comment V.D. Patel Oct. 7, 2019 JA3585 1075. Comment Carol Landry Oct. 7, 2019 JA3587 1076. Comment Virginia Ann







Oct. 3, 2019 JA3603




lviii

VOLUME 22

1091. Comment Jae Gruenke Oct. 4, 2019 JA3619 1092. Comment Laura Webb Oct. 4, 2019 JA3621 1093. Comment Andrea J



Oct. 4, 2019 JA3625


Oct. 4, 2019 JA3627


Oct. 4, 2019 JA3629



Oct. 4, 2019 JA3635

1100. Comment Roberta Bolduc Oct. 4, 2019 JA3637 1101. Comment Diane Harrison Oct. 4, 2019 JA3639 1102. Comment Thomas Keen Oct. 4, 2019 JA3641 1103. Comment Ann Zavala Oct. 4, 2019 JA3643 1104. Comment Lisa Meserve Oct. 4, 2019 JA3645 1105. Comment James Laba Oct. 7, 2019 JA3647 1106. Comment Randy and




1109. Comment Steffani LaZier Nov 4, 2019 JA3655


lix

1110. Comment Claire Viadro Oct. 31, 2019 JA3657 1111. Comment Joni Aarden,


Oct. 30, 2019 JA3659




Oct. 7, 2019 JA3669


Oct. 7, 2019 JA3671

1118. Comment Ralph Thomas Oct. 7, 2019 JA3673 1119. Comment Kevin Metke Oct. 8, 2019 JA3675 1120. Comment Kate Inserra Oct. 3, 2019 JA3677 1121. Comment Nicole Lawson Oct. 7, 2019 JA3679 1122. Comment Kathy Bates Jul 26, 2019 JA3681 1123. Comment KathyMcComm

on Jun. 18, 2019 JA3683






Oct. 7, 2019 JA3693

1129. Comment Tamara Jackson Oct. 3, 2019 JA3695 1130. Comment Catherine Hunn Oct. 2, 2019 JA3697


lx

1131. Comment Joanne Halpin Jun. 21, 2019 JA3699 1132. Comment Oscar Perez Jun. 20, 2019 JA3701 1133. Comment Theresa Quiroz Jun. 20, 2019 JA3703 1134. Comment Melinda


1135. Comment D. Emmel Jun. 19, 2019 JA3707 1136. Comment David John

Smith Jr. Oct. 2, 2019 JA3709

1137. Comment Tessa Lachman Oct. 2, 2019 JA3711 1138. Comment Elayne

Candiotte May 22, 2020 JA3713

1139. Comment Rebecca Hull Oct. 2, 2019 JA3715 1140. Comment John Snyder Oct. 2, 2019 JA3717 1141. Comment Sue Newton,


1142. Comment Robert Weinberger

May 21, 2020 JA3721

1143. Comment Nancy Wallace Jun. 17, 2019 JA3723 1144. Reply Mary Beth


1145. Comment Nina Beety Jun. 4, 2019 JA3730 1146. Ex Parte Jodi Nelson Jun. 4, 2019 JA3723 1147. Ex Parte Kevin Mottus Sep 15, 2020 JA3735 1148. Comment Elizabeth



Oct. 2, 2019 JA3757

1150. Comment Nina Beety Jun. 18, 2019 JA3759 1151. Comment James S.

Wazorick Jun. 17, 2019 JA3765


lxi

1152. Comment Deborah Chandler

Jun. 18, 2019 JA3767

1153. Comment C. Zehfus Oct. 2, 2019 JA3769 1154. Comment Stephanie

Thomas Jun. 18, 2019 JA3772


Jun. 4, 2019 JA3774

1156. Comment John Frink Jun. 4, 2019 JA3776 1157. Reply Comment Kimberly

Modesitt Jun. 10, 2019 JA3778

1158. Comment Elaine Unger Jun. 17, 2019 JA3780 1159. Reply Mark Wahl Jun. 5, 2019 JA3784 1160. Comment Phoebe Sorgen Jun. 4, 2019 JA3786 1161. Comment Elise Godown Jun. 18, 2019 JA3788 1162. Comment Jeannette

Hassberg Jun. 3, 2020 JA3790

1163. Comment Kim Hahn Jun. 3, 2019 JA3792 1164. Comment Mark

McDonald Jun. 18, 2019 JA3794

VOLUME 23

1165. Comment Debra Grayley, Brian Grayley, Dorothy Cherney, Erwin Arnold

Jun. 19, 2019 JA3796

1166. Comment Michele Altman Jun. 4, 2019 JA3798 1167. Comment Charmane

Vaianisi Jun. 17, 2019 JA3800

1168. Comment Sam Parish Jun. 17, 2019 JA3802 1169. Comment Jennifer Sohns Jun. 18, 2019 JA3804 1170. Comment Robert

Anservitz, Lynne

Jun. 18, 2019 JA3806


lxii

Anservitz, Alex Anservitz

1171. Comment Center for Safer Wireless

Jun. 18, 2019 JA3808


Jun. 18, 2019 JA3810


Jun. 18, 2019 JA3812

1174. Comment Marissa Brand, Colin Brand

Oct. 3, 2019 JA3814

1175. Comment Susan Peters Jun. 4, 2019 JA3816 1176. Comment Cary Terrall May 22, 2020 JA2818 1177. Comment Raymur



Jun. 6, 2019 JA3822


Keith Jun. 17, 2019 JA3826

1181. Comment Gloria Shen Oct. 3, 2019 JA3828 1182. Comment Ellen Marks Jun. 18, 2019 JA3830 1183. Comment Kate Inserra Oct. 3, 2019 JA3832 1184. Comment Susan

Waterman Jun. 18, 2019 JA3834

1185. Comment Heidi Junger Jun. 18, 2019 JA3836 1186. Comment Rebecca Hull Oct. 2, 2019 JA3838 1187. Comment Bruce J. Miller Oct. 1, 2019 JA3840 1188. Comment Sue Newton,



Jun. 4, 2019 JA3844

1190. Comment Nina Beety Jun. 4, 2019 JA3846


lxiii


Jun. 3, 2019 JA3849

1192. Reply Comment Oklahoma City et al

Jun.17, 2019 JA3851

1193. Ex Parte Kevin Mottus Sep 15, 2020 JA3866 1194. Comment Elizabeth


1195. Comment Citizens for Health, Kate Kheel

Jun. 18, 2019 JA3888


Oct. 2, 2019 JA3892

1197. Reply Comment Dan Kleiber Jun. 18, 2019 JA3894 1198. Comment Nina Beety Jun. 18, 2019 JA3903 1199. Comment Kathleen Heller Oct. 7, 2019 JA3909 1200. Comment Debra R. Van

Dusen Oct. 15, 2019 JA3911

1201. Comment Angela Tsiang Jun. 18, 2019 JA3913 1202. Comment Melissa

Corinne Senger Jun. 17, 2019 JA3919

1203. Comment Lise Sheehan Jun. 18, 2019 JA3921 1204. Comment Jennifer Breeze Jun. 17, 2019 JA3923 1205. Comment Joseph T



Jun. 3, 2019 JA3927

1207. Comment Virginia Farver Jun. 3, 2019 JA3929 1208. Comment Nancy Hirsch Jun. 17, 2019 JA3931 1209. Comment Debora Cantel Jun. 18, 2019 JA3933 1210. Comment John Frink Jun. 4, 2019 JA3935


lxiv


Jun. 10, 2019 JA3937

1212. Reply Mark Wahl Jun. 5, 2019 JA3939 1213. Comment Matt


1214. Comment Sara Vandenbos Jun. 14, 2019 JA3943 1215. Comment Peg Peterson Jun. 17, 2019 JA3945 1216. Comment J. Adamo Jun. 17, 2019 JA3947 1217. Comment John Crewdson Jun. 18, 2019 JA3949 1218. Comment Meg Oberreuter Jun. 17, 2019 JA3951 1219. Comment Stephanie

Walker Jun. 18, 2019 JA3953

1220. Comment Heather Harper Jun. 18, 2019 JA3955 1221. Comment Deborah,

Tennant Jun. 18, 2019 JA3957


Jun. 18, 2019 JA3959

1223. Comment Heather Wenger

Jun. 18, 2019 JA3961


Jun. 18, 2019 JA3963

1225. Comment Anne Carpenter Jun. 18, 2019 JA3965 1226. Comment Brita Light,

Garrett Rodsdale

Oct. 4, 2019 JA3967

1227. Comment Douglas Matson

Jun. 2, 2019 JA3969


Oct. 7, 2019 JA3971


Jun. 6, 2019 JA3973

1230. Comment Diane Royal Oct. 7, 2019 JA3975


lxv


Jun. 17, 2019 JA3977

1232. Comment Elayne Candiotte

May 22, 2020 JA3979

VOLUME 24

1233. Comment Nancy Kaiser Jun. 18, 2019 JA3981 1234. Comment Rebecca Hull Oct. 2, 2019 JA3983 1235. Comment Sue Newton,


1236. Comment Robert Weinberger

May 21, 2020 JA3987


Jun.3, 2019 JA3989

1238. Comment Jonathan Mirin Jun.18, 2019 JA3991 1239. Comment Nancy Wallace Jun.17, 2019 JA3993 1240. Reply Mark Wahl Jun.5, 2019 JA3995 1241. Comment Chuck Hinz Jun.18, 2019 JA3997 1242. Comment Cindy Sallis Jun.18, 2019 JA3999 1243. Comment Debora Cantel Jun.18, 2019 JA4001 1244. Comment Deborah

Kopald Jun.18, 2019 JA4003


Jun.10, 2019 JA4006

1246. Comment Matt Huntington

Jun.17, 2019 JA4008

1247. Comment Kim Hahn Jun.3, 2019 JA4010 1248. Comment Cynthia Price Jun.17, 2019 JA4012 1249. Comment Emily Lanxner Jun.17, 2019 JA4014 1250. Comment S.C. Jennings Jun.17, 2019 JA4016 1251. Comment Rebecca Liepke Jun.1, 2020 JA4018 1252. Comment Lindsa Vallee Jun.4, 2019 JA4020 1253. Comment Sheila Smith-

Ramirez Jun.17, 2019 JA4022


lxvi

1254. Comment Catherine Fish Jun.18, 2019 JA4024 1255. Comment Dawn Koeper Jun.18, 2019 JA4026 1256. Comment Mary Nickell Jun.18, 2019 JA4028 1257. Comment Lucina Melissa

Lohse Jun.18, 2019 JA4030

1258. Comment Lynette Yetter Jun.18, 2019 JA4032 1259. Comment Peter Morton,

Anna Marie Morton

Jun.6, 2019 JA4034


JA4036

1261. Comment Ina Cottingham Oct.7, 2019 JA4038 1262. Comment Jill Krutick Jun.17, 2019 JA4040 1263. Comment Zoe Berg Jun.17, 2019 JA4042 1264. Comment Toby Stover Oct.3, 2019 JA4044 1265. Comment Dr. Lora

Chamberlain Oct.7, 2019 JA4046


Jun.4, 2019 JA4048

1267. Comment Kirstin Beatty, Last Tree Laws Director

May 28, 2019 JA4050


Jun. 10, 2019 JA4052

1269. Comment M. Tomko Jun. 17, 2019 JA4054 1270. Comment Denise King,

Autumn King,Holly King

Jun.18, 2019 JA4056

1271. Comment Elaine Unger Jun. 17, 2019 JA4058 1272. Reply Mary Beth


1273. Reply Mark Wahl Jun. 5, 2019 JA4067


lxvii

1274. Comment Lori Vanderhider

Oct. 1, 2019 JA4069


Oct.7, 2019 JA4071

1276. Comment Peggy Nigro Oct.8, 2019 JA4073 1277. Comment Geoffrey Shuey Jun.17, 2019 JA4075 1278. Comment Maxina Ventura Jun.17, 2019 JA4077 1279. Comment Matt

Huntington Jun.17, 2019 JA4079

1280. Comment Karen Rogers Jun.18, 2019 JA4082 1281. Comment Cindy Ladig Jun.17, 2019 JA4084 1282. Comment Victoria Sievers Jun. 4, 2019 JA4086 1283. Comment Jana Harris Jun.17, 2019 JA4088 1284. Comment Phoebe Sorgen Jun. 4, 2019 JA4090 1285. Comment Kimberly

Kohlmann Jun.18, 2019 JA4092

1286. Comment Jessica Holl Jun.18, 2019 JA4094 1287. Comment Erin Sintros Oct.2, 2019 JA4096 1288. Comment Deborah

Ladermann D.C.

Jun.18, 2019 JA4098

1289. Comment Stephen Dahl Oct.2, 2019 JA4100 1290. Comment Samantha

Tuinstra Jun.17, 2019 JA4102

1291. Comment Mayara Carneiro

Jun. 17, 2019 JA4104

1292. Comment Yumi Wong Jun. 17, 2019 JA4106 1293. Comment Warren


1294. Comment Jacquelyn Griffith

Jun. 18, 2019 JA4110

1295. Comment Susan Straus Jun.18, 2019 JA4112 1296. Comment Peg Peterson Jun. 17, 2019 JA4114


lxviii

1297. Comment Cathy Izzo Jun. 18, 2019 JA4116 1298. Comment Miguel Trujillo Jun. 18, 2019 JA4118 1299. Comment Frederica

Graham Jun. 18, 2019 JA4120

1300. Comment J. Copp Jun. 18, 2019 JA4122 1301. Comment Dale A.

Benjamin Jun. 19, 2019 JA4124

1302. Comment Anne Wilder Oct. 17, 2019 JA4126 1303. Jeannette

Hassberg Jun. 3, 2020 JA4128


Oct. 3, 2019 JA4130

1305. Comment Kelly Marcotulli

Jun. 17, 2019 JA4132

1306. Comment Cathy Cooke Jun. 14, 2019 JA4134 1307. Comment J. Adamo Jun. 17, 2019 JA4136 1308. Comment Alyssa L.

Barnes Jun. 17, 2019 JA4138

1309. Comment Peggy Williams Jun. 17, 2019 JA4140 1310. Comment Jack Rossi Jun. 17, 2019 JA4142 1311. Comment Leo B Cashman Jun. 17, 2019 JA4144 1312. Comment Gayle Casas,


Jun. 17, 2019 JA4146

1313. Comment Cynthia Price Jun. 17, 2019 JA4148 1314. Comment Emily Lanxner Jun. 17, 2019 JA4150

VOLUME 25

1315. Comment SC Jennings Jun. 18, 2019 JA4152 1316. Comment Clara Chapman Jun. 18, 2019 JA4154 1317. Comment Debra Grayley,

Brian Grayley, Dorothy

Jun. 19, 2019 JA4156


lxix

Cherney, Erwin Arnold


Jun. 18, 2019 JA4158

1319. Comment Sheilajean Whitefield

Jun. 18, 2019 JA4160

1320. Comment Laura Woodruff Jun. 19, 2019 JA4162 1321. Comment Rebecca Liepke Jun. 1, 2020 JA4164 1322. Comment Michele Altman Jun. 4, 2019 JA4166 1323. Comment Marilynne

Martin Jun. 4, 2020 JA4168

1324. Comment Lindsa Vallee Jun. 4, 2019 JA4170 1325. Comment Holly Johnson Jun. 4, 2019 JA4172 1326. Comment Ron Ward Jun. 5, 2019 JA4174 1327. Comment John F. Cowan Jun. 17, 2019 JA4176 1328. Comment Stephanie

Austin Jun. 17, 2019 JA4178

1329. Comment Nancy Wallace Jun. 17, 2019 JA4180 1330. Comment Annmarie

Schroeder Jun. 17, 2019 JA4182

1331. Comment Lucy Yang Jun.17, 2019 JA4184 1332. Comment Sheila Smith-

Ramirez Jun. 17, 2019 JA4186

1333. Comment Cynthia Price Jun. 17, 2019 JA4188 1334. Comment Michele Lance Jun. 17, 2019 JA4190 1335. Comment Nancy L.

Wagner Jun. 17, 2019 JA4192


Jun. 17, 2019 JA4194

1337. Comment John Crewdson Jun. 18, 2019 JA4196 1338. Comment Meg Oberreuter Jun. 17, 2019 JA4198 1339. Comment Sam Parish Jun. 17, 2019 JA4200


lxx

1340. Comment Stephanie Walker

Jun. 18, 2019 JA4202

1341. Comment Richard Yount Jun. 18, 2019 JA4204 1342. Comment Siochai

O’Connor Jun. 18, 2019 JA4206

1343. Comment Catherine Fish Jun. 18, 2019 JA4208 1344. Comment Heather Harper Jun. 18, 2019 JA4210 1345. Comment Stanley Banos Jun. 18, 2019 JA4212 1346. Comment Eli Dumitru Jun. 18, 2019 JA4214 1347. Comment Anna L. Marsh Jun. 18, 2019 JA4216 1348. Comment Lynda Schartle Jun. 18, 2019 JA4218 1349. Comment Deborah

Tennant Jun. 18, 2019 JA4220

1350. Comment Jennifer Sohns Jun. 18, 2019 JA4222 1351. Comment Denise Allen,

Robert Allen Jun. 18, 2019 JA4224


Jun. 18, 2019 JA4226

1353. Comment Jennifer Aerts Jun. 18, 2019 JA4228 1354. Comment Dawn Koeper Jun. 18, 2019 JA4230 1355. Comment Robert

Anservitz, Lynne Anservitz, Alex Anservitz

Jun. 18, 2019 JA4232

1356. Comment Michelle Khatana

Jun. 18, 2019 JA4234

1357. Comment Mary Nickell Jun. 18, 2019 JA4236 1358. Comment Marylin Olds Jun. 18, 2019 JA4238 1359. Comment Center for Safer

Wireless Jun. 18, 2019 JA4240

1360. Comment Beverley Birks Jun. 18, 2019 JA4242


lxxi


Jun. 18, 2019 JA4244

1362. Comment Mark Ahlheim Jun. 18, 2019 JA4246 1363. Comment Jenni Johnson Jun. 18, 2019 JA4248 1364. Comment Larissa Lyles Jun. 18, 2019 JA4250 1365. Comment John Simonsen Jun. 18, 2019 JA4252 1366. Comment Heather

Wenger Jun.18, 2019 JA4254


Jun. 18, 2019 JA4256


Jun. 18, 2019 JA4258

1369. Comment Karen Gamal Jun. 18, 2019 JA4260 1370. Comment Erin Blanc Jun. 18, 2019 JA4262 1371. Comment Melissa Petrini Jun. 18, 2019 JA4264 1372. Comment Paula Boyer Jun. 18, 2019 JA4267 1373. Comment Michelle

Rowton Jun. 19, 2019 JA4269

1374. Comment David Morrow, Amanda Morrow

Oct. 1, 2019 JA4271

1375. Comment Lynda Smith, Thomas Cowan, M.D.

Oct. 3, 2019 JA4273

1376. Comment Marissa Brand, Colin Brand

Oct. 3, 2019 JA4275

1377. Comment Brita Light, Garrett Rodsdale

Oct. 4, 2019 JA4277

1378. Comment Susan Peters Jun. 4, 2019 JA4279 1379. Comment Cary Terrall May 22, 2020 JA4281 1380. Comment Raymur



lxxii


Jun. 6, 2019 JA4285


Keith Jun. 17, 2019 JA4289

1384. Comment L. Koenes Oct. 3, 2019 JA4291 1385. Comment Ina Cottingham Oct. 7, 2019 JA4293 1386. Comment Gloria Shen Oct. 3, 2019 JA4295 1387. Comment Diana Corbett,


1388. Comment Ellen Marks Jun. 18, 2019 JA4299 1389. Comment Jill Krutick Jun. 17, 2019 JA4301 1390. Comment Lauren Galvin Jun. 18, 2019 JA4303 1391. Comment Richard H





Oct. 3, 2019 JA4313



VOLUME 26






lxxiii












Oct. 1, 2019 JA4353


Oct. 3, 2019 JA4355


Oct. 3, 2019 JA4357


Oct. 3, 2019 JA4359

1419. Comment Sandi Maurer Oct. 2, 2019 JA4361 1420. Comment Roy Lamkin Oct. 2, 2019 JA4363 1421. Comment Jennifer



Oct. 2, 2019 JA4367


Oct. 2, 2019 JA4369


lxxiv




Oct. 3, 2019 JA4385


Oct. 2, 2019 JA4387


Oct. 3, 2019 JA4389


Angelina Laubsch, Alan Laubsch, Bertrand Laubsch, Celine Laubsch

Oct. 3, 2019 JA4395






Oct. 3, 2019 JA4405

1442. Comment Kim Stribling Oct. 3, 2019 JA4407


lxxv

1443. Comment Susan Long, John Long, Hanna Long, Sara Long, Trevor Barker, Jordan Sego, Hanna Sego, Rebeka Long, Jack Morgan

Oct. 3, 2019 JA4409

1444. Comment Mary Thomas Oct. 4, 2019 JA4411 1445. Comment James Wecker Oct. 4, 2019 JA4413 1446. Comment James Laba Oct. 7, 2019 JA4415 1447. Comment Karen Gadol Oct. 7, 2019 JA4417 1448. Comment Sita Ryan Oct. 7, 2019 JA4419 1449. Comment J.A. Blahnik Oct. 7, 2019 JA4421 1450. Comment Gabriele Steiner Oct. 7, 2019 JA4423 1451. Comment William S.



Oct. 7, 2019 JA4427




Oct. 7, 2019 JA4433



1461. Comment Kelly Metke Oct. 8, 2019 JA4445 1462. Comment Susan Stewart Oct. 8, 2019 JA4447


lxxvi

1463. Comment Jocelyn Horst Oct. 8, 2019 JA4449 1464. Comment Bonnie





Oct. 3, 2019 JA4457



1475. Comment Jae Gruenke Oct. 4, 2019 JA4473 1476. Comment Laura Webb Oct. 4, 2019 JA4475 1477. Comment Andrea J.



Oct. 4, 2019 JA4479


Oct. 4, 2019 JA4481


Oct. 4, 2019 JA4483

1481. Comment Jenna Nelson Oct. 4, 2019 JA4485


lxxvii

1482. Comment Raina Stewart Oct. 4, 2019 JA4487 VOLUME 27

1483. Comment Dianna Bessette, Matt Olson

Oct. 4, 2019 JA4489

1484. Comment Roberta Bolduc Oct. 4, 2019 JA4491 1485. Comment Diane Harrison Oct. 4, 2019 JA4493 1486. Comment Thomas Keen Oct. 4, 2019 JA4495 1487. Comment Ann Zavala Oct. 4, 2019 JA4497 1488. Comment Lisa Meserve Oct. 4, 2019 JA4499 1489. Comment James Laba Oct. 7, 2019 JA4501 1490. Comment Randy and

Cindy Baker Dec. 5, 2019 JA4503





Oct. 30, 2019 JA4513




Oct. 7, 2019 JA4523


Oct. 7, 2019 JA4525


lxxviii

1502. Comment Ralph Thomas Oct. 7, 2019 JA4527 1503. Comment Kevin Metke Oct. 8, 2019 JA4529 1504. Comment Marcel Longpre Jun. 18, 2019 JA4531 1505. Comment Judy Caruso Jun. 18, 2019 JA4533 1506. Comment Christine Heady Jun. 18, 2019 JA4535 1507. Comment Karen Palmer Jun. 18, 2019 JA4537 1508. Comment Elizabeth Kroll Jun. 18, 2019 JA4539 1509. Comment Elizabeth Bates Jun. 18, 2019 JA4541 1510. Comment Kate Inserra Oct. 3, 2019 JA4543 1511. Comment Susan B.

Samoriski, Ed.D

Jun. 18, 2019 JA4545

1512. Comment Laurie Bloom Jun. 18, 2019 JA4547 1513. Comment Nicole Lawson Oct. 7, 2019 JA4549 1514. Comment Kathy Bates Jul 26, 2019 JA4551 1515. Comment KathyMcComm

on Jun. 18, 2019 JA4553






Oct. 7, 2019 JA4563




lxxix

1527. Comment D. Emmel Jun. 19, 2019 JA4577 1528. Comment Zoe Berg Jun. 17, 2019 JA4579 1529. Comment Susan

Waterman Jun. 18, 2019 JA4581

1530. Comment Oscar Perez Jun. 20, 2019 JA4583 1531. Comment Kevin Vidrine Jun. 18, 2019 JA4585 1532. Comment Victor Almeida Jun. 17, 2019 JA4587 1533. Comment Jane



Oct. 2, 2019 JA4591

1535. Comment Tessa Lachman Oct. 2, 2019 JA4593 1536. Comment Nick Quinlan Jun. 18, 2019 JA4595 1537. Comment Keely Barnett Jun. 18, 2019 JA4597 1538. Comment Elayne

Candiotte May 22, 2020 JA4599

1539. Comment Elaine Unger, John Unger

Jun. 18, 2019 JA4601


Jun. 18, 2019 JA4603

1541. Comment Larry Oppriecht Jun. 17, 2019 JA4605 1542. Comment Heidi Junger Jun. 18, 2019 JA4607 1543. Comment Lauren Farina Jun. 17, 2019 JA4609 1544. Comment Nancy Kaiser Jun. 18, 2019 JA4611 1545. Comment Frank Kaanoi Jun. 18, 2019 JA4613 1546. Comment Linda Kean Jun. 18, 2019 JA4615 1547. Comment Rebecca Hull Oct. 2, 2019 JA4617 1548. Comment Tania Teschke Jun. 18, 2019 JA4619 1549. Comment Kelley Barnes-

Valdes Jun. 18, 2019 JA4621


Jun. 18, 2019 JA4623


lxxx

1551. Comment Theresa, Nielsen

Jun. 19, 2019 JA4625

1552. Comment John Snyder Oct. 2, 2019 JA4628 1553. Comment Katelyn

VonMyhr Oct. 1, 2019 JA4630

1554. Comment Bruce J. Miller Oct. 1, 2019 JA4632 1555. Comment Sue Newton,


1556. Comment Molly Brown Jun. 17, 2019 JA4636 1557. Comment Allison Bagg Jun. 17, 2019 JA4638 1558. Comment William

Bensussen Jun. 17, 2019 JA4640

1559. Comment Deana Eichenstein

Jun. 17, 2019 JA4642

1560. Comment John C Pronchik

Jun. 18, 2019 JA4644


Jun. 18, 2019 JA4646

1562. Comment Jim Turner Jun. 18, 2019 JA4648 1563. Comment Brandi Graham Jun. 18, 2019 JA4650 1564. Comment Judy Kosovich Jun. 17, 2019 JA4652


Biological and Health Effects of Microwave Radiofrequency Transmissions

A Review of the Research Literature

Dr. Paul Dart (2013)

JA0506


Paul Dart MD FCA3495 Harris StreetEugene, OR 97405September 1, 2013

Federal Communications Commission

r.e. Comments on Notice of Inquiry, ET Docket No. 13-84

Dear Sirs,

I am part of a medical advisory group that has spent the last 18 months researching thecurrent medical literature on the biological or “non-thermal” effects of microwave radiofrequency transmissions, in an effort to assist the Eugene Water and Electric Board inmaking prudent decisions on their choices of technology as they consider installing anAMI infrastructure of RF–transmitting “smart” electric meters. This document containsthe product of our efforts—an extensive written review of the research to date onbiological effects of RF.

Also attached to this filing are five pdf documents from an audiovisual presentation onthis subject, illustrating research evidence for adverse effects including EHS(electrohypersensitivity syndrome), alterations in hormone physiology, DNA damage,cancer, infertility, and increased brain tumor risk from cell phones.

The FCC has not chosen to implement any safety standards regarding non-thermaleffects of microwave RF exposure. But the existing literature demonstrates that there issignificant cause for concern regarding the growing impacts of these exposures on thepublic. Research documenting their adverse biologic and health effects is robust now.The implications of this research cannot be discounted, and must not be ignored.

The FCC should request that the EPA impanel a Working Group composed of healthexperts who have no conflicts of interest with industry to review the scientific literatureon EMR. The Group should recommend biologically–based EMR standards that ensureadequate protection for the general public and occupational health based upon theprecautionary principle. Finally, the FCC should adopt the standards, testingprocedures, and appropriate precautionary warning language recommended by theWorking Group.

It would be indefensible at this time for the FCC to take any actions that may increaseexposure of the population to EMR from cell phones, base stations, Wi-Fi, Smart Metersand other RF or ELF–emitting devices. The current levels of exposure need to bereduced rather than increased further. The FCC must especially protect vulnerablegroups in the population including children and teenagers, pregnant women, men ofreproductive age, individuals with compromised immune systems, seniors, andworkers.

Sincerely yours,

Paul Dart MD FCA

Comments on Notice of Inquiry, ET Docket No. 13-84

JA0507


BIOLOGICAL AND HEALTH EFFECTS OFMICROWAVE RADIO FREQUENCY

TRANSMISSIONS

A REVIEW OF THE RESEARCH LITERATURE

A REPORT TO THE STAFF AND DIRECTORS OFTHE EUGENE WATER AND ELECTRIC BOARD

June 4, 2013

Paul Dart, M.D.(lead author)

Kathleen Cordes, M.D.

Andrew Elliott, N.D.

James Knackstedt, M.D.

Joseph Morgan, M.D.

Pamela Wible, M.D.

Steven Baker(technical advisor)


JA0508


EXECUTIVE SUMMARYThe FCC regulations for permissable exposures to microwave radio frequency

(RF) transmissions are only designed to protect against the thermal effects of high expo-sure levels. Representatives of the telecommunications industry usually assert thatthere is “no clear or conclusive” scientific evidence regarding the biological effects oflow level or “nonthermal” RF exposures. But in actuality, a large body of scientificresearch documents that RF exposures at low levels can produce adverse biological orhealth effects.

The installation of RF-transmitting “smart meters” by our electric utility couldsignificantly increase the level of RF exposure in Eugene’s residential neighborhoods.Such an increase carries potential health risks. The nature of these risks needs to becarefully considered before making a decision to deploy this technology.

Any decision-making process that ignores this possibility of harm could causesignificantly damage both to community health and to EWEB’s goodwill in thecommunity.

ELECTROHYPERSENSITIVITY (EHS)Microwave RF exposures can produce acute symptoms in some individuals.

These symptoms can include headache, sleep disturbance, difficulty in concentration,memory disturbance, fatigue, depression, irritability, dizziness, malaise, tinnitus,burning and flushed skin, digestive disturbance, tremor, and cardiac irregularities. Thissyndrome was described by Russian researchers in the 1950’s, who called it “microwavesickness”. Between 1953 and 1978 the Russian government purposefully targeted theU.S. embassy in Moscow with beams of microwave RF, producing symptoms ofmicrowave sickness in many embassy employees.

In recent years, the buildout of the wireless telecommunications infrastructurehas greatly increased the exposure of the general public to microwave RF, and this hasled to an increased number of individuals experiencing symptoms that are now referredto as “Electrohypersensitivity Syndrome” (EHS). Multiple research studies have showna correlation between these symptoms and residential exposure to radio, radar, and celltower transmissions.

The prevalence of EHS appears to be increasing, as the exposure of the public toRF continues to expand. Based on recent epidemiologic research, it would be reason-able to assume RF exposures provoke some sort of symptoms in between 3 and 5% ofthe population of Eugene at the current time. Any significant increase in residential RFexposure is likely to make these individuals more symptomatic, and to produce somenew cases of EHS by pushing some other individuals beyond their tolerance limit.

ALTERED PHYSIOLOGYLaboratory research in animal and human subjects has shown that “nonthermal”

levels of RF exposure can alter EEG, immune function, and hormone levels includingadrenal and thyroid hormones, testosterone, prolactin, progesterone.

Research shows that low levels of microwave RF exposure can reduce melatoninlevels in humans, and that some individuals are more sensitive than others to this effect.The adverse effects of nighttime RF exposure on melatonin secretion are particularydisturbing. The nocturnal rise in melatonin levels supports the natural function ofsleep, and disrupting this cycle can produce insomnia. Melatonin is an extremelypotent antioxidant, and helps to repair damaged DNA and heal the body from other

i


JA0509


effects of oxidant stress.Melatonin is also protective against the growth of cancer cells, and disruption of

the circadian melatonin cycle has been shown to lead to increased tumor growth in avariety of cancer types. Women who have lower levels of nocturnal melatonin are atgreater risk for developing breast cancer. Reduced melatonin levels may also increasethe incidence of prostate cancer.

OXIDATIVE STRESS AND DAMAGED DNAIn contrast with Xrays and gamma rays, Microwave radiation does not have

sufficient power to directly break covalent bonds in DNA molecules. But microwaveRF can produce resonance interactions with ions and with charged macromolecules,and such interactions can significantly alter biochemical functions. A large body ofresearch has shown that microwave RF causes an increased production of free radicalsand reactive oxidant species in living tissues, and that this increased oxidant stressdamages DNA. This damage can and does occur at power levels well below thoselevels that could produce damage by thermal mechanisms.

Any chronic exposure to conditions that damage DNA can lead to an increasedrisk of cancer. Evidence of increased risk of certain types of cancer has been demons-trated in groups with occupational exposure to microwave RF, including radio techni-cians in private industry, military personnel, commercial airline pilots, and ham radiooperators. Elevated levels of cancer have been demonstrated in populations withincreased residential exposure to radio transmission towers. And in the last ten years,studies fro Israel, Germany, Austria, and Brazil have documented significant increasedin breast cancer and other cancers in individuals living less than 500 meters from cellphone towers, with measured exposure levels much lower than those permitted bycurrent FCC guidelines.

Research has also shown that RF exposure levels well within current guidelinescan cause DNA damage and reduced fertility in insects, birds, amphibians andmammals, and can lower sperm counts, sperm motility, and sperm motility in humanbeings.

RISKS OF CELL PHONE USECell phone use expanded dramatically in Europe and the United States in the late

1990’s. Early studies of the cancer risks of cell phone use were hampered by shortlatency periods of exposure. In general, studies funded by industry have reportedlower levels of risk than independently funded studies. But in the last four years, allbut the most poorly designed studies have shown an increased risk of brain tumorswith more than ten years of use—a level of exposure which appears to double the riskof brain tumor on the side of the head where the cell phone is customarily held. Thisrisk is higher in those who started using cell phones as children.

CONCLUSIONSExisting scientific research offers strong evidence that the chronic exposure of the

public to microwave RF transmissions produces serious acute and chronic health effectsin a significant portion of the population. These findings can be summarized in thefollowing precepts:

EXECUTIVE SUMMARY

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Basic Precepts for Residential Exposures to RF Transmissions: • Excessive RF exposure can cause acute problems (headaches, insomnia, fatigue,

vertigo, tinnitus, other symptoms of EHS).• Excessive RF exposure can also cause chronic problems (oxidative stress, cancer,

male infertility).• Constant RF transmission is probably harmful, even at low levels, and should be

avoided.• Frequent and repetitive intermittent transmissions are also probably harmful,

and should be avoided.• Nocturnal exposures are more problematic than daytime exposures, because of

RF’s potential to suppress nocturnal melatonin secretion and disturb sleep, andbecause night is the time when we rest and heal from stresses (including oxida-tive stress).

• Occasional and infrequent daytime exposures are much less likely to cause anincrease in chronic problems for the population at large.

• Occasional and infrequent daytime exposures are still likely to provoke acutesymptoms in a small percentage of the population.

EWEB should adopt a policy of minimizing their RF footprint in the community.A recognition of these precepts should lead EWEB to adopting a policy of mini-

mizing their infrastructure’s RF footprint in the community as much as possible duringregular operations. This doesn’t mean that staff would throw away their cell phonesand communicate by semaphore. But it would mean that instead of combatting or igno-ring the possibility that more RF in the community could cause harm, EWEB shouldacknowledge the potential risks of excessive residential exposure.

This would mean that such potential risks would be seriously considered in anydiscussion of the total risks and benefits involved (the “Total Bottom Line”), as EWEBdecides whether to use RF technology for any given purpose. If, after such a discussion,a considered decision is made to use RF technology, then these same potential risksshould be taken into serious consideration in determining how to use this technology ina manner that would minimize potential harm to the community.

In other words, don’t use RF when you don’t have to. Use hard-wired connec-tions wherever it is feasible to do so. And if you do use RF, design the infrastructure ina way that uses as little of it as possible.

In the final section of this report, we discuss the perspectives that such a policymight bring to a consideration of the available AMI technologies.

EXECUTIVE SUMMARY

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TABLE OF CONTENTS

PREFACE vii

INTRODUCTION 1

ELECTROHYPERSENSITIVITY 9

RADIOFREQUENCY EFFECTS ON MELATONIN 23

RF EXPOSURE INCREASES OXIDATIVE STRESS AND DAMAGES DNA 31

CURRENT RESEARCH ON CELL PHONE USE AND BRAIN TUMOR 57

CONCLUSIONS AND RECOMMENDATIONS 67

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PREFACEThis paper represents the efforts of a group of physicians who have been in

private practice in Eugene for decades. Our concerns are for the health of our patientsas well as for our community as a whole.

When EWEB proposed installing a “mesh” smart meter network we becameconcerned. We know that there are people in this community who are highly sensitiveto electromagnetic fields. The installation of the smart meter mesh would makeEugene a much more hostile environment for these individuals.

We also know that chronic exposures to microwave radio frequency (RF) trans-missions can produce adverse long term physiological effects, even in individuals whodo not consciously experience acute symptoms from exposure to such electromagneticfields.

As we considered these issues, we were not sure if the policy makers at EWEBhad sufficient current and applicable scientific information upon which to rely, as theyevaluated the potential health effects of such an implementation. EWEB may havereferred to FCC guidelines, without considering that the FCC regulations on radiofrequency (RF) exposure are only designed to protect against the thermal effects ofextremely high level RF exposures, and do not attempt to define a safe level of protec-tion against other biological effects.

Because of these concerns, we have undertaken a sixteen month long investiga-tion of the scientific literature, in order to present what we feel is a valid scientific basisfor evaluating the potential health effects of a community-wide RF smart meter installa-tion. This paper presents our findings to you.

We have organized this report into six sections:1. An introduction into some of the issues involved in the “smart meter”

Advanced Metering Infrastructure. 2. A review of the scientific research documenting the existence of acute

reactions to “non-thermal” levels of RF exposure -- reactions which intheir most severe form are called electrohypersensitivity syndrome(EHS).

3. A review of the function of melatonin, of evidence that RF exposurecan suppress melatonin, and of the short and long term consequencesof melatonin suppression.

4. A review of the long term effects of RF exposure, especially theproduction of oxidative stress that can lead to DNA damage andincreased levels of cancer and infertility.

5. A review of current research regarding relationship of cellular andcordless telephone use to increased risk of brain tumors.

6. A discussion of our conclusions and recommendations to EWEB, basedon this review of the scientific literature.

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INTRODUCTIONAMI and the Smart Energy Grid

The Advanced Metering Infrastructure (AMI) technology is a key component ofthe smart energy grid that we heard discussed in very general terms in the 2008 presi-dential election. During the past two years, EWEB has been actively exploring thepossibility of installing AMI in Eugene.

EWEB staff have described several purposes for going to an AMI “smart meter”infrastructure, including the following:

Reducing operating costsRemote reading of meters would eliminate meter readers, allowing EWEB to

save substantial costs in employee time and benefits, vehicle use, and gasoline costs.Smart meters can also be used to turn power on and off remotely, saving labor andtravel costs when rentals become vacant or occupied.

Shifting time of useSmart meters can measure and record total power usage for several intervals

during the day. This will allow EWEB to bill customers more for electrical usage atpeak use hours, typically the early morning (when people are getting up, takingshowers, cooking breakfast) and late afternoon/early evening (when people returnhome from work, cook dinner, take showers, throw some clothes in the laundry, etc.).Time of use billing could create an incentive for customers to shift elective usage(laundry, recharging the electric car) away from peak usage hours.

Electrical utilities need enough generating capacity to meet peak demand. Redu-cing or restraining the growth of peak usage could reduce or slow the need to buildmore power generating capacity into the system.

Training customers to conserve electricitySmart meter technology can allow home owners to monitor their usage in real

time over a home network with the meter. EWEB hopes that this direct feedback willencourage people to reduce their energy consumption.

“Demand/Response” infrastructureEWEB has invested a great deal in wind power. But the wind tends to blow

hardest in the middle of the day and the middle of the night. At dawn and dusk (peakusage times for electrical consumers) the wind is more likely to calm down.

This creates a storage problem for the utility. When wind power production ishigh during the night, production can exceed demand, generating more electricity thancan be used locally or sold interstate.

One way to distribute and store this energy is to put it in your water heater. Twoway communication with your Smart Meter could allow the power company to turnyour water heater on for 15 minutes in the middle of the night or the middle of the day,at a time when it would otherwise not be on [they can’t turn it on for two hours, when itgets to the maximum heat setting the thermostat will turn it off]. EWEB would seekcustomers willing to volunteer to allow this arrangement.

With “demand/response” control, EWEB could store excess wind power as heatby turn on clusters of water heaters for 15 minutes, then turn them off and turn on otherclusters of water heaters, and continue to rotate the usage around the communityduring the middle of the night.

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Solar power generation creates another storage problem. Solar panel output canfluctuate rapidly during the day with changing cloud cover. Too sudden an increase inlocal production from multiple large panels could overload the grid. The AMI infra-structure would allow the utility to tell Smart Meters to turn off solar panel input intothe electrical grid. Again, this requires rapid two-way communication between theutility and the Smart Meter, and between the Smart Meter and the solar panel in thehouse.

From an engineering point of view, the simplest and cheapest way to install thiscommunications infrastructure is to have the meters communicate with the utility andwith the “smart appliances” in the home using wireless microwave radio technology.

The use of this wireless technology for AMI communications has generated agood deal of political heat in the last two or three years. To understand where this heathas come from, it is instructive to review the history of the Pacific Gas and ElectricCompany’s smart meter rollout in California.

PG&E in California, 2010 – 2011In 2010 and 2011 PG&E rolled out an AMI infrastructure in multiple cities in

California. The metering technology that they chose to install was the Silver SpringsAMI “smart meter”. These meters communicate with the utility by forming a “mesh”network in the neighborhood. The meters communicate with each other rather thanwith a central receiver, and pass data through this MESH network to the central collec-ting system of the electric utility.

The installation of such technology places a radio transmitter on every house inthe community. Concerns about the potential health effects of this residential RF expo-sure led several members of the California Assembly to request that the CaliforniaCouncil on Science and Technology (CCST) perform a study of whether current FCCstandards for Smart Meters were sufficiently protective of the public health, andwhether additional standards might be needed for such technology.

It should be noted that the regulatory standards established by the FederalCommunications Commission are based on defining safe levels against the thermaleffects of microwave radio frequency (RF) exposure (i.e. “Will it cook you?”) Forexample, the FCC has established Limits for Maximum Permissible Exposure (MPE).(FCC, 1999, page 15). The FCC has explicitly stated that they do not make any regula-tions or assurances whatsoever regarding the “nonthermal” biological effects ofmicrowave exposure (other physiologic effect besides heat damage). (Hankin, 2002)

The CCST released a report on “Health Impacts of Radio Frequency from SmartMeters” in January, 2011. (CCST, 2011) This report stated (on page 5) that Smart Meter-ing technology met the FCC standards for “safety against known thermally inducedhealth impacts”. It also stated (on page 4) that “To date, scientific studies have not identi-fied or confirmed negative health effects from potential non-thermal impacts of RF emissionssuch as those produced by existing common household electronic devices and smart meters. Notenough is currently known about potential non-thermal impacts of radio frequency emissions toidentify or recommend additional standards for such impacts.” The CCST report concludedthat “There is no evidence that additional standards are needed to protect the public from smartmeters.” (page 26)

When the Draft Version of this CCST report was released, several experts in thefield of research that studies the biological effects of RF communicated their disagree-

SECTION 1 – INTRODUCTION

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ment with the study’s conclusions. It was pointed out that the content of the CCSTdocument was in major part a repetition of a document produced by the industry-spon-sored Electric Power Research Institute a few weeks before (Tell, 2010), and that theanalysis of AMI smart meter exposure levels in the report was incorrect in its design.(Hirsch, 2011)

These experts offered evidence of multiple scientific studies documenting thenonthermal health impacts of RF. (Sage, 2011b) (Johansson, 2011) Independentresearch was presented to the CCST documenting that the Silver Springs metersproduced levels of household exposures significantly higher than levels shown to haveadverse health effects in current scientific research. (Sage, 2011a)

These objections from the scientific community did not alter the CCST’s stanceon smart meters, which continued to be installed in California.

What happened next in CaliforniaPG&E’s approach to the AMI rollout didn’t involve a lot of public education.

They just switched out the meters. And some people found that they were havingtrouble sleeping, or experiencing headaches, ringing in the ears, vertigo, or other symp-toms that hadn’t been bothering them before. Soon the internet was awash in anecdotalreports and commentary about these adverse effects. (emfsafetynetwork.org, 2011)

PG&E’s public posture was that the meters only transmitted for an average of 45seconds per day. They asserted that the total power output over time was well belowthe FCC guidelines for thermal risk, and well below that of other RF exposures in thecommunity. Videos began to crop up on You Tube showing that the picture wasn’t thatsimple (for example, http://www.youtube.com/user/thisirradiatedlife/featured).

Finally PG&E was served with a court order to provide clear documentation ofwhat the meters actually were doing. (Yip-Kikugawa, 2011) In the response to thatcourt order, PG&E provided documentation from the manufacturer of the meters thatthe average meter in the mesh network transmitted data signals to the utility 6 times aday, network management signals 15 times a day, timing signals 360 times a day, andbeacon signals to the mesh network 9,600 times a day. (Kim et al., 2011) This penciledout to an average of roughly 7 transmissions a minute, 24 hours a day, coming out ofevery meter in the community.

As reports of provoked symptoms increased, the situation became more andmore politically heated. Santa Cruz County banned the installation of smart meters.PG&E continued to install them, and the Santa Cruz County Sheriff’s office refused toenforce the ban. Individuals started purchasing refurbished analogue electric metersand swapping them out themselves, attempting to return the smart meters to the utility.PG&E publicly stated (a week or two before Christmas) that they would turn off thepower of anyone who removed a smart meter from their service box—but backed downfrom that threat due to public backlash.

By the end of 2011, multiple cities in California had either banned smart metersor placed a moratorium on their continued installation, and a lawsuit has been filedagainst PG&E with the California Public Utilities Commission. (Wilner, 2011)

EWEB’s Elster MESH AMI TrialIn 2010 EWEB set up a trial of AMI infrastructure, using the Elster REX2 Smart

Meter. Like the Silver Springs meter used by PG&E in California, the REX2 operates ona mesh network. The meters upload usage data to a central collection meter 4 to 6 times


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a day, but transmit short beacon signals to the network several times a minute.EWEB stated on their website that these meters transmit “less than 10 seconds a

day”. But they were unable to state how frequently transmissions actually occurred. Inour communications with their public relations staff, we were told that Elster was un-willing to release this information. Information on the power output of these meters isavailable on the ELSTER website. (TUV Rheinland, 2010) But Elster does not discussthe actual frequency of transmission of the meters.

In January 2012 we used a Gigahertz Solutions HF35C analyzer to evaluate theoutput of one of these Elster meters in a residential neighborhood in Eugene.

Background RF signals coming through the neighborhood were measured in a360 degree circle around the monitoring position. The background RF averaged around4 microwatts/square meter (μW/m2), increasing to 8 or 10 μW/m2 when we aimed ourdirectional antenna at the radio towers on Blanton Heights or at a distant cell phonetower.

The Elster meter’s transmission rate was variable. In our observations, they aredefinitely transmitting several times a minute, sometimes 4 or 5 times a minute, andoccasionally in bursts of significantly higher frequency.

At 5 feet from the smart meter, the peak strength of the beacon signal coming offthe meter measured from 3800 to 11,000 μW/m2. At 20 feet from the meter, the powerdensity of the signal ranged from 362 to 493 μW/m2, with occasional bursts at higherpower output.

This means that at a distance of 20 feet the power of the signal coming out of theElster meter was about 100 times the power of the ambient background signal comingfrom any specific direction in the residential neighborhood.

This power density of 300+ to 400+ μW/m2 was greater than the signal strengthof the cell phone tower at 29th and Amazon, measured from about 200 meters away. Sofilling a neighborhood with a mesh network of the Elster smart meters would be similarto placing every house in that neighborhood closer than 200 meters from a cell phonetower, each house constantly being pinged by the chatter of multiple beacon signalsfrom the mesh.

This was disconcerting, since recent research has shown that people living within500 meters of a cell phone tower have increased incidence of headache, concentrationdifficulties, and sleep disorders, and also a significantly increased risk of some types ofcancer. (Khurana et al., 2010) (Levitt and Lai, 2010) (Yakymenko et al., 2011) (Altpeteret al., 2006) (Abdel-Rassoul et al., 2007)

When you put these facts together, it is not so surprising that the installation ofmesh smart meter networks in residential neighborhoods in California last year wasfollowed by a surge of anecdotal evidence regarding headaches, insomnia and otherhealth complaints. From a medical perspective, based on a familiarity with currentresearch on the biological effects of RF, this was a predictable consequence of PG&E’ssmart meter MESH network rollout.

Formation of our Advisory CommitteeBy late 2011 EWEB staff were working towards setting a specific timeline for

installing AMI in Eugene. From our perspective, the potential health risks of such aproject did not appear to have received any realistic discussion. EWEB’s web siteimplied that such risks were inconsequential. In January of 2012 EWEB’s Public Rela-


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tions staff started to test a public relations campaign promoting the AMI project. Theirinitial presentation minimized the possibility any health risks from this exposure.

Some physician members of our group became involved in discussions withEWEB staff. In these discussions, we tried to learn more about the technologies underconsideration from EWEB engineers, and in turn we attempted to communicate ourconcerns about the potential health risks of this technology.

It became clear to us that EWEB staff did not have the time or the expertise toresearch this issue of health risks in any depth. Our sense of this was confirmed inApril of 2012, when EWEB management presented the AMI Business Case to the EWEBBoard. The discussion of “Potential Health Risks” in this document quoted governmentagency reports as if they were scientific studies, and stated that in an “attempt to discoverif there were any credible studies showing any health effect caused by long-term RF exposure inrelatively high dosages (e.g. exposures much greater than an AMI meter) . . . no conclusiveevidence was found that indicates that this higher magnitude RF exposure has created adversehealth impacts.”

EWEB is a locally owned utility with a lot of goodwill in the community. Wewere concerned that if EWEB continued forward without taking a deeper look at thisissue, decisions might be made that would have the potential to cause significant harmto the health of the community, or to create political strife that could significantlydamage EWEB’s local standing.

In an effort to help EWEB think this problem through in a more complete andconsidered fashion, we decided to form a group of physicians and other professionalswith scientific and engineering expertise. Over the past 16 months, our group hasstudied the scientific literature on the biological effects of microwave RF. This report isthe result of our efforts.

We hope that EWEB’s staff and Board will examine this information carefully,and that it will help them to make prudent choices as they consider the various AMItechnologies that are currently available to them.


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BIBLIOGRAPY

Abdel-Rassoul G, El-Fateh OA, Salem MA et al. Neurobehavioral effects among inhabi-tants around mobile phone base stations. Neurotoxicology (2007); 28(2):434-440.

Altpeter ES, Roosli M, Battaglia M, Pfluger D, Minder CE, Abelin T. Effect of short-wave(6-22 MHz) magnetic fields on sleep quality and melatonin cycle in humans: theSchwarzenburg shut-down study. Bioelectromagnetics (2006); 27(2):142-150.

CCST. Health Impacts of Radio Frequency From Smart Meters. California Council on Science and Technology (2011); 1-50. http://www.ccst.us/news/2011/20110111smart.php

EMF Safety Network. Smart Meter Health Complaints. (2011/10/17); 1-59.http://emfsafetynetwork.org/?page_id=2292

FCC. Questions and Answers about Biological Effects and Potential Hazards of Radio-frequency Electromagnetic Fields. OET Bulletin 56, Fourth Edition, FederalCommunications Commission, Office of Engineering and Technology. (1999); 1-38.http://transition.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet56/oet56e4.pdf

Hankin N. Letter from N. Hankin, Center for Science and Risk Assessment, RadiationProtection Division, United States Environmental Protection Agency, to Ms. JaneNewton, President, The EMR Network. (2002); 1-3.

Hirsch D. Comments on the Draft Report by the California Council on Science andTechnology “Health Impacts of Radio Frequency from Smart Meters”.(2011); 1-11. http://www.ccst.us/projects/smart2/documents/letter8hirsch.pdf

Johansson O. Letter to California Public Utilities Commission (CPUC) re Smart Meters.(2011); 1-3. http://www.scribd.com/doc/59738917/Dr-Johansson-s-letter-re-SmartGrid-Smart-Meter-dangers-to-CPUC-7-9-2011

Khurana VG, Hardell L, Everaert J, Bortkiewicz A, Carlberg M, Ahonen M. Epidemiolo-gical evidence for a health risk from mobile phone base stations. Int J OccupEnviron Health (2010); 16(3):263-267.

Kim A, Chonda J, Law Department PGE. Pacific Gas and Electric Company’s Responseto Adminstrative Law Judge’s October 18, 2011 Ruling Directing It to FileClarifying Radio Frequency Information. (2011/11/1); http://sunroomdesk.com/wp-content/uploads/2011/11/PGERResponsesRFDataOpt-outalternatives_11-1-11-3pm.pdf

Levitt B, Lai H. Biological effects from exposure to electromagnetic radiation emitted bycell tower base stations and other antenna arrays. Environ Rev (2010); 18:369-395.

Milham S, Morgan LL. A new electromagnetic exposure metric: high frequency voltagetransients associated with increased cancer incidence in teachers in a Californiaschool. Am J Ind Med (2008); 51(8):579-586.

Sage C. Assessment of Radiofrequency Microwave Radiation Emissions from SmartMeters. ed. Santa Barbara, CA: Sage Associates, 2011a: 1-100. http://sagereports.com/smart-meter-rf/

Sage C. Letter of Comment on Smart Meter Report. Sage Associates, 2011b: 1-6.http://www.ccst.us/projects/smart2/documents/letter12sage.pdf

Sensus. FlexNet System Specifications. (AMR-456-R2). 2011a: http://www.sensus.com/documents/10157/32460/amr_456.pdf


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Sensus. SUS-1004 FlexNet Brochure. 2011b: http://www.sensus.com/documents/10157/31649/SUS-1004_FlexNet_Brochure_seperated.pdf

Tell R. An Investigation of Radiofrequency Fields Associated with the Itron SmartMeter. EPRI 2010 Technical Report Electric Power Research Institute, (2010); 1-222.http://my.epri.com/portal/server.pt/gateway/PTARGS_0_2_1630_405_228188_43/http%3B/myepri10%3B80/EPRIDocumentAccess/popup.aspx?DeepLinking=false/000000000001021126

TUV Rheinland of North America. RF Exposure Report: Rex2 Power Meter. Elster Solu-tions, LLC. (2010); 1-3. http://www.naperville.il.us/emplibrary/Smart_Grid/RFexposurereport-RX2EA4.pdf

Wilner D. Wilner & Associates vs. Pacific Gas and Electric Company. Before the Cali-fornia Public Utilities Commission of the State of California. (2011/10/26); 1-19. http://docs.cpuc.ca.gov/published/proceedings/C1110028.htm

Yakymenko I, Sidorik E, Kyrylenko S, Chekhun V. Long-term exposure to microwaveradiation provokes cancer growth: evidences from radars and mobile communica-tion systems. Exp Oncol (2011); 33(2):62-70.

Yip-Kikugawa A. Administrative Law Judge’s Ruling Seeking Clarification. Before the Public Utilities Commission of the State of California. (2011/10/18): 1-4.http://docs.cpuc.ca.gov/EFILE/RULINGS/145652.PDF


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ELECTROHYPERSENSITIVITY“MICROWAVE SICKNESS"

Acute symptoms provoked by microwave radiation were first described byRussian medical researchers in the 1950’s. They described a constellation of symptomsincluding headache, ocular dysfunction, fatigue, dizziness, sleep disorders, dermato-graphism, cardiovascular abnormalities, depression, irritability, and memory impair-ment. (Liakouris, 1998)

In the years between 1953 and 1978 the Russian government harrassed the U.S.Embassy in Moscow by targeting it with radiation from a microwave transmitter.Concern about health effects led to a detailed study by A.M. Lilienfeld, an epidemiolo-gist at Johns Hopkins University. (Lilienfeld AM, 1979)

The abnormalities found in this study were an embarrassment to the U.S.government, since the levels of exposure experienced by embassy staff were in theorder of 2 to 28 microwatts/cm2, a level dramatically below the described U.S. safetystandards for microwave exposure. The conclusions of the study were altered to soft-pedal any abnormal findings. (Goldsmith, 1995b) (Cherry, 2000)

But outside epidemiologic analysis of the Lilienfeld report’s published datashowed that exposed embassy staff experienced a statistically significant excess ofseveral problems, including depression, irritability, difficulty in concentrating, memoryloss, ear problems, skin problems, vascular problems, and other health problems.Symptom incidence increased significantly with accrued years of exposure. (Golds-mith, 1995a) (Cherry, 2000)

THE EMERGENCE OF "ELECTROHYPERSENSITIVITY" AS A DIAGNOSISIn recent years the buildout of cellular communication networks has created a

markedly increased exposure of the public to RF transmissions. Each new generation ofcell phone technology has occupied a higher frequency on the microwave scale, withpotentially increasing impact on body physiology. (Cherry, 2002) As this has occurred,mounting evidence has pointed to the fact that a percentage of the population experi-ences adverse reactions associated with these exposures. The term “electrohypersensiti-vity” (EHS) has been used to describe a constellation of symptoms, including headache,sleep disturbance, difficulty in concentration, memory disturbance, fatigue, depression,irritability, dizziness, malaise, tinnitus, burning and flushed skin, digestive disturbance,tremor, and cardiac irregularities. Sleep disturbance, headache, nervous distress,fatigue, and concentration difficulties are the most commonly described symptoms.(Roosli et al., 2004)

These symptoms are identical to the symptoms of “microwave sickness”described by Russian physicians in the 1950’s.

SYMPTOMS PROVOKED BY TRANSMISSION TOWERSIn 2002, Santini reported significant increases in such symptoms in individuals

living closer than 300 meters to cell towers. (Santini et al., 2002) (Santini R, 2003) In Poland, Bortkiewicz found similar increases in symptoms among residents

near cell towers. Symptoms showed equal association to proximity of the tower,regardless of whether or not the subject suspected such a causal association. (Bortkie-wicz et al., 2004) (Bortkiewicz et al., 2012)

In two studies, Abelin and Altpeter found evidence of disruption of sleep cycle

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and melatonin physiology by RF transmission during the operation and subsequentshutdown of the short wave radio transmitter in Schwarzenburg, Switzerland. (Abelinet al., 2005) (Altpeter et al., 2006)

Figure 1: Percentage of subjects reporting symptoms, stratified by RF exposurelevels as measured in subject’s bedroom. (Hutter et al., 2006)

In a study done in urban and rural sites in Austria, Hutter found a clearly signifi-cant correlation between exposed signal power density and headaches and concentra-tion difficulties—despite the fact that maximum measured power densities were only4.1 mW/m2 (= 0.41 µW/cm2, well below established “safe” limits). (Hutter et al., 2006)

Figure 2: Percentage of subjects reporting symptoms, stratified by proximity tocity’s first cell phone tower. (Abdel-Rassoul et al., 2007)

SECTION 2 – ELECTROHYPERSENSITIVITY

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In Egypt, a study of inhabitants living near the first cell phone tower in the city ofShebeen El-Kom found a significant increase in headaches, memory changes, dizziness,tremors, depressive symptoms, and sleep disturbance, with lower performance on testsof attention and short-term auditory memory. (Abdel-Rassoul et al., 2007)

Research at the military radar installation in Akrotiri, Cyprus, showed that resi-dents of exposed villages had markedly increased incidence of migraine, headache,dizziness, and depression, and significant increases in asthma, heart problems, andother respiratory problems. (Preece et al., 2007)

Studies in Murcia, Spain yielded similar findings, and based on measured expo-sures the authors suggested that safe levels of indoor exposure should not exceed1 µW/m2 (0.0001 µW/cm2) (Navarro et al., 2003) (Oberfeld et al., 2004)

In a study of residents of Selbitz, Bavaria, researchers found statistically signifi-cant increases in multiple health symptoms that demonstrated a dose-response relation-ship with cell phone tower transmissions. Individuals living within 400 meters of thecell phone tower had significantly more symptoms than those living > 400 meters fromthe tower. And individuals living within 200 meters of the tower had significantlyhigher symptoms than those living between 200 and 400 meters from the tower. (Egerand Jahn, 2010)

Two recent reviews provide a detailed overview of research in this area.(Khurana et al., 2010) (Levitt and Lai, 2010)

SYMPTOMS PROVOKED BY CELL PHONE USEMultiple studies of cell phone users in the last decade found evidence of a similar

pattern of symptoms to be provoked in some users. (Chia et al., 2000) (Oftedal et al.,2000) (Santini R, 2002) (Wilen et al., 2003) (Salama and Abou El Naga, 2004) (Al-Khlaiwi and Meo, 2004) (Balikci et al., 2005) (Balik et al., 2005) (Szyjkowska et al.,2005) (Meo and Al-Drees, 2005) (Soderqvist et al., 2008) (Landgrebe et al., 2009)(Hutter et al., 2010)

PHYSIOLOGY OF ELECTROHYPERSENSITIVITYA variety of research models have demonstrated that RF exposure does not have

a uniform effect on people. In many studies, a cohort of individuals has been identifiedthat has a more sensitive response to RF in one way or another.

Reduced heart rate variabilityIn one study, patients with symptoms consistent with EHS were found to have

dereased circadium changes in heart rate variability. (Lyskov et al., 2001) Similarchanges in HRV were found in another study where subjects self-identified as havingEHS symptoms from exposure to video display terminals, TV screens, fluorescentlights, or other electrical equipment. (Sandstrom et al., 2003) An occupational study ofRF plastic sealer workers also found alterations in heart rate compared to normalcontrols.

Fatigue and reduced melatoninIn the more recent Schwarzenberg study, the effect of RF exposure on producing

morning fatigue and reduced melatonin secretion was significantly greater in thesubjects whose general quality of sleep was below the median. (Altpeter et al., 2006)


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EEG changesAlterations in EEG have been found in animals and in people with exposure to

both magnetic fields and cell phone transmission frequencies. (Marino et al., 2003)(Marino et al., 2004)

Nanou et al found the EEG response to be gender dependent after exposure bothto 900 MHz and 1800 MHz signals. (Nanou et al., 2005) (Nanou et al., 2009)

Bachman found EEG changes with 450 MHz microwave exposure in 25 to 30% ofhealthy volunteers (Bachmann et al., 2005) (Bachmann et al., 2006). In another study,EEG changes were 5 times as common in depressive subjects as in healthy controls.(Bachmann et al., 2007)

Landgrebe found decreased intracortical excitability in EEG after transcranialmagnetic stimulation in self-identified EHS patients, as compared with normal controls.(Landgrebe et al., 2007)

Schmidt found alteration in sleep EEG after exposure to a 900 MHz RF signalmodulated at two different frequencies, and noted a marked individual variation insensitivity to this effect. (Schmid et al., 2011)

Loughran found alterations in non-REM EEG after cell phone RF exposure.These alterations were consistently stronger in one subset of his study group, overmultiple tests. (Loughran et al., 2012)

Altered Immune FunctionExposure to both GSM and UMTS cellular transmissions at nonthermal exposure

levels have been shown to alter DNA repair mechanisms in lymphocytes. (Markova etal., 2005) (Belyaev et al., 2009) Multiple additional studies have demonstrated non-thermal biological effects of RF radiation on immune cell function, as reviewed here.(Johansson, 2007) (Johansson, 2009b)

One of the most intriguing findings is Johannson’s research showing that pati-ents with electrosensitivity have higher levels of mast cells in their skin, and that thesemast cells migrate closer to the skin surface. (Johansson, 2006) Mast cells are respon-sible for the itching, burning, and skin flushing that occurs after sunburn exposure. Thepresence of higher levels of mast cells in EHS patients provides an explanation for thesymptoms of flushed, itching, and burning skin on the face and other areas that isdescribed by these patients, who appear to be reacting to RF exposure like others mightreact to excessive sun exposure. Since mast cells are distributed throughout the body,the presence of mastocytosis in EHS patients may relate to some other symptoms aswell.

Hormonal ChangesChronic exposures to electromagnetic field effects have also been shown to cause

alterations in secretion of multiple hormones. A study published in 2007 showed thatphysiotherapists working with various electromagnetic treatment modalities had signi-ficantly elevated secretion levels of the stress hormones cortisol, adrenaline, and nor-adrenaline. (Vangelova et al., 2007)

Another study measured urinary secretion of the stress hormones adrenaline andnoradrenaline, along with levels of dopamine and phenylethylamine, prior to and overthe 1 1/2 years following the installation of a GSM cell phone tower in Rimbach,Bavaria. Levels of adrenaline and noradrenaline showed a significant increase over thefirst six months after exposure, and never returned to baseline levels. Responses


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showed a proportional relationship to residential exposure levels, and were clearlypresent at levels as low as 60 to 100 microwatts/m2 (= 0.006 to 0.010 μW/cm2). Thissuggested a chronic stress effect of the GSM microwave signal on the population.(Buchner K, 2011)

Chronic adrenal stress will in time lead to decompensation and symptoms ofadrenal fatigue in a certain percentage of the population.

A recently published study evaluated human hormone profiles over six years ofexposure to the microwave RF emissions of GSM cell phones or cell phone towers.Findings included highly significant decreases in ACTH, cortisol, both T4 and T3thyroid hormones. In male subjects, serum testosterone levels gradually decreased withincreased time of exposure. In females, alterations in serum prolactin and progesteronelevels gradually increased over increased time of exposure. (Eskander et al., 2012)

Current ResearchOne of us had the opportunity this spring to visit the practice of Dr. Dominique

Belpomme, Professor of Oncology at Paris Descartes University, who is conductingresearch on electrohypersensitivity with the Association for Research and TreatmentsAgainst Cancer (ARTAC) in Paris. The ARTAC group has been following severalhundred patients with EHS over the last four years, and has documented that thesepatients have clear and consistent changes in oxidative metabolism, and also in bloodflow to the limbic system (as measured by doppler studies). Dr. Belpomme considersthese changes in the limbic system to directly correlate with many of the cognitivechanges (memory problems, difficulty with concentration, etc.) that are experienced bythese patients. The ARTAC group expects to publish a series of papers on their findingsduring the next year. (Dart, 2012)

PROVOCATION STUDIESOver the last ten years, many attempts have been made to evaluate the nature of

electrohypersensitivity through provocation studies. The limitations of these studieshave been discussed in detail in some recent papers. (Loughran et al., 2012) (Regel andAchermann, 2011)

Problems of methodology that have compromised many provocation studiesinclude:

• Many studies have been performed single-blind rather than double-blind.• Many studies divide the study group and normal controls based on the indivi-

dual’s self-identification as having (or not having) electrohypersensitivity.Since it is certainly possible for people to have reactions to EMF without beingaware of this connection, and since the entire population is exposed to EMF atthis point in time, it is difficult to be sure that the “control” group is indeedcomposed of “non-reactors”. This will tend to weaken the power of any studyset up in this fashion.

• Many studies evaluate whether or not the subject can discern when the RFsignal is present and when it is absent. Absence of the ability to make thisjudgement is taken as evidence that electrohypersensitivity does not exist. Thisis an extremely illogical assumption. A person can develop a headache duringor after an RF exposure without knowing when the signal is “on” or “off”, justas they can develop bacterial gastroenteritis without knowing what food wascontaminated with the bacteria. Having symptoms from RF and being a reli-


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able RF meter are not the same thing.• Unspecified or inadequate control of background levels of RF/EMF is also a

problem with some “negative” studies. For example, one recent study (Kim etal., 2008) was performed with background RF levels in the study area of of 0.5,0.7, and 0.8 V/m from three different mobile phone service providers. Thisadds up to a reported 2.0 V/m of background RF, equivalent to several thou-sand microwatts/m2, which is well above threshold levels reported to causesymptoms in many sensitive individuals.

• Many studies assume that all patients who complain of EHS will react to anyconstant RF signal, and that they will react to it every time. Yet some studieshave demonstrated that patients vary in which frequencies they respond to, andthat patients can react more strongly to the starting and stopping of a signalthan they do to the presence of a steady signal.

• Furthermore, the assumption is often made that EHS symptoms will start whena signal is turned on, and stop when it turns off. These assumptions are proble-matic, since many patients with EHS report having symptoms that continue fora significant time (hours, in many cases) after a triggering exposure. Fewstudies discuss whether or not an adequate “washout time” was provided forbefore starting the study, or between provocational challenges. The absence ofsuch washout times seriously weakens the power of these studies.

In order to do a reliable RF provocation study with EHS exposure, it is necessaryto isolate the subjects from background RF levels, and to maintain them in this isolationfor long enough that they stop reacting to any prior exposures which they havereceived, before attempting to provoke a new reaction.

Some studies that are designed to address all these methodologic issues havefound clear evidence of electrosensitivity. For example, a study done in 1991 that wasperformed in an isolated EMF environment tested EHS patients with a variety of diffe-rent frequencies of RF stimulus, to determine their individual reactivity spectrum. 100patients who identified themselves as having electrohypersensitivity were tested singleblind with a variety of RF frequencies. 25 of these 100 patients showed an increase insymptoms of 20% over baseline, with no more than one placebo response.

These 25 patients were retested in a double blind setting with 25 healthy controls.16 of the 25 patients (64%) reacted to the positive challenges, which were performed at avariety of frequencies.

These 16 patients reacted to 53% of the 336 active challenges, and 7.5% of the 60blanks. No patient reacted to all tested frequencies. The 25 healthy controls had noreactions to challenges or to blanks.

Finally, these 16 patients were again tested in a double blind setting, each patientchallenged with the single frequency to which they were most sensitive. In this phaseof the study, the patients reacted 100% of the time to the active transmissions (with bothreported symptoms and autonomic changes on iriscorder) and did not report reactionsto the sham transmissions. (Rea et al., 1991)

It must be reiterated that having an adverse reaction to a provoking RF signaland having the ability to determine when the signal is “on” and when it is “off” are twocompletely different things. A recent double blind study demonstrated that a patientcan have consistent provocation of symptoms from a signal without having any clearawareness of when the signal is actually present. (McCarty et al., 2011)


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These provocation studies involve short term exposures to the RF signal (typi-cally an hour or less). Since a great deal of the physiology research shows a morepowerful effect with chronic exposures, these short-term studies are probably not themost effective way to assess the clinical significance of reactions to RF.

PREVALENCE OF EHSResearch in Stockholm County, Sweden in 1997 found that 1.5% of the popula-

tion reported being hypersensitive to electrical or magnetic fields. (Hillert et al., 2002)In California in 1998, Levallois et al found that 3.2% of the adult population

reported being sensitive to sources of EMF. (Levallois et al., 2002) In Switzerland in 2004, researchers studying a representative sample of the Swiss

population found that 5% of the population had symptoms attributable to EHS, withsleep disorders and headaches being the most common reported symptoms. (Schreieret al., 2006)

In Austria in 2004, 2% of the population was estimated to have electrohypersen-sitivity. In a survey performed in Austria in 2008, 29.3% of respondents reportedhaving some sort of adverse response to electromagnetic pollution. Of this cohort, 2.1%reported intense disturbance, and 3.5% had experienced enough difficulty that they hadconsulted a physician about the problem. (Schrottner and Leitgeb, 2008)

Figure 3: The prevalence of electrohypersensitivity syndrome is increasing.(Hallberg and Oberfeld, 2006

In much of the world, exposure to microwave radio signals has continued tosignificantly increase since the early 1990’s. Reported electrosensitivity also appears tobe increasing over time. In 2006, Halberg and Oberfeld reviewed research on thissubject from 1985 forward, and estimated that if the trend in increased prevalence conti-nues, fifty percent of the population could be reporting adverse effects from EMF by theyear 2017 (Figure 1). (Hallberg and Oberfeld, 2006)


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GOVERNMENTAL RESPONSEThe various forms of research described above have provided strong support for

the fact that RF/EMF exposures can produce symptoms in human beings and that thereis a percentage of the population that is more sensitive to this effect. Continuedresearch is suggesting that this is not a static situation—that the prevalence of electro-hypersensitivity is a growing over time.

By the middle of the last decade, various government agencies were attemptingto define the scope of the problem. (Irvine, 2005)

The rollout of mobile phone technology occurred earlier in scandinavia than inother places in the world, and governmental recognition of EHS as a health problemoccurred earlier there than in other places. By the year 2000, EHS was recognized as adisability by the Swedish government. (Ministers, 2000)

In Stockholm, individuals with EHS can receive municipal support to reduce thepresence of and penetration of EMF/RF into their homes. The construction of a villagewith houses specifically designed to mitigate this problem is being considered. Patientswith EHS have the legal right to receive mitigations in their workplace, and some hospi-tals have build low EMF hospital rooms for use by such patients. (Johansson, 2006)

Various government reports or reviews on the question of electrohypersensiti-vity have been commissioned in the last few years. (Aringer et al., 1997) (Irvine, 2005)And legislation to address the problem has been proposed in some countries. (Snoy,2011) (Parliamentary Assembly, 2011) Many libraries and schools in europe havebanned WiFi due to concerns about health effects on employees and on the public.

REGULATORY RESPONSERegulations on exposure limits vary dramatically from country to country. In

general, exposure limits have been mandated at a lower level in Russia and easternEurope, where research on the health effects of RF exposure has been performed for alonger period of time. (Repacholi et al., 2012)

The regulatory standards established by the FCC and the World Health Organi-zation are based on defining safe levels against the thermal effects of RF (i.e. damagefrom being cooked by high levels of microwave exposure). The FCC has not establishedexposure standards for potential nonthermal or biological effects of microwave expo-sure. (Hankin, 2002)

For example, the FCC has established Limits for Maximum Permissible Exposure(MPE). For the general population, the permissible level of exposure at 900 MHz is 600μW/cm2, and at 1800 MHz is 1000 μW/cm2. (FCC, 1999) These exposure levels werelast updated in 1996, and are considered to be protective against thermal effects ofmicrowave radiation. However, current scientific research shows that these permissiblelevles of exposure are hundreds of times higher than the threshold levels for adverse“nonthermal” biological effects.

For the past ten years, the WHO has consistently equivocated on the issue ofrecognizing nonthermal biological effects from microwave RF exposure, despite themounting research evidence of health problems and health risks produced by currentlevels of public exposure.


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The following table shows exposure standards for various countries in 2001.(Firstenberg, 2001)

Figure 2: RF exposure limits (2001)

PHYSICIAN AND RESEARCHER RESPONSEIn response to this inaction on the part of government and international regula-

tory bodies over the past decade, a variety of groups of physicians and researchers inthe field of RF/EMF health effects have called for regulatory action to address the docu-mented biological consequences of the increasing exposure of the public to RFtransmissions.

In 2000, the Salzburg Resolution suggested a total high frequency radiation limitof 100 mW/m2 (10 µW/cm2), and a total emission level of pulse modulated exposure(such as GSM) of 1 mW/m2 (0.1 µW/cm2). (Altpeter et al., 2000)

In 2002 a group of German physicians described a growing problem withadverse clinical effects from RF/EMF, and called for stricter safety limits on RF trans-missions, restrictions on cell phone use by children and adolescents, and a ban oncellular and cordless phone use in preschools, schools, hospitals, nursing homes, eventhalls, public buildings, and vehicles. (2002)

Multiple similar appeals have been made by research groups and medical associ-ations over the past ten years. (Association, 2004) (Leitgeb et al., 2005) (Association,2012) (Dean A, 2012) (Johansson, 2011) (Johansson, 2009a) (Fragopoulou et al., 2010)(Israel et al., 2011)


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Vangelova K, Israel M, Velkova D, Ivanova M. Changes in excretion rates of stresshormones in medical staff exposed to electromagnetic radiation. Environmentalist(2007); 27(4):551-555.

Wilen J, Sandstrom M, Hansson Mild K. Subjective symptoms among mobile phoneusers--a consequence of absorption of radiofrequency fields? Bioelectromagnetics(2003); 24(3):152-159.


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RADIOFREQUENCY EFFECTS ON MELATONINTHE FUNCTION OF MELATONIN

Many physiologic functions in the human body are entrained in a circadiumrhythm, fluctuating through the day/night cycle. The hormone melatonin, secreted bythe pineal gland, is a key agent in coordinating these physiologic responses throughoutthe body. (Zawilska et al., 2009)

The entrainment of melatonin secretion with the day/night cycle is maintainedby the suprachiasmatic nucleus in the hypothalamus, which receives input on thepresence of light from the retina via the retinohypothalamic tract. In the presence ofambient light, melatonin secretion is suppressed. In the absence of ambient light, mela-tonin secretion increases. So melatonin secretion is high during the nighttime hours,peaking shortly after midnight. Higher melatonin levels are part of what makes us feel“sleepy” at night. Exposure to light during the nighttime hours will lead to a rapidsuppression of melatonin secretion by the pineal gland, and this can cause disruption ofsleep and derangement of the circadium rhythm.

Since the length of the day varies seasonally, melatonin also provides our physio-logy with information and influence produced by the different seasons of the year. Thisseasonal influence was obviously more profound prior to the widespread introductionof artificial electric lighting.

The circadian rhythm of high nocturnal melatonin levels supports the naturalfunction of sleep, and disruption of this rhythm by bright light at night, night shiftwork, or travel to different time zones can produce sleep disturbances.

Melatonin is one of the most potent antioxidant molecules in the human body,and acts to reduce reactive oxidative processes in the body. Melatonin can quench thedamaging free radical activity produced by inflammation. The presence of elevatedmelatonin at night is therefore a key factor in the healing and rejuvenating functionsthat we associate with “a good night’s sleep”.

Many body processes (serum cortisol levels, body temperature, patterns of diges-tive function, etc.) have a circadian rhythm that is coordinated by the timing signal ofmelatonin secretion. Melatonin has a protective effect on the health of the gastrointes-tinal tract. Melatonin is also protective against the growth of cancer cells, and disrup-tion of the circadian melatonin cycle has been shown to lead to increased tumor growthin a variety of cancer types. (Reiter et al., 2011)

Research has clearly demonstrated that melatonin inhibits the proliferation, inva-siveness, and metastasis of human breast cancer cells. Women who have lower levels ofnocturnal melatonin are at greater risk for developing breast cancer. (Schernhammer etal., 2008) (Schernhammer and Hankinson, 2009) Breast cancer is more common inindustrialized societies, and geographically the incidence of breast cancer is stronglyassociated with higher levels of “light-at-night”. (Kloog et al., 2008) (Kloog et al., 2010)

Current research suggests that disruption of nocturnal melatonin signals by“light at night” can promote both the development and the growth of breast cancer.(Hill et al., 2011) (Stevens, 2009) In 2007 the International Agency for Research onCancer declared night shift work to be a probable carcinogen. Subsequent epidemio-logic research continues to support this finding. (Bonde et al., 2012)

Recent research has also suggested similar associations between “light at night”and the incidence of prostate cancer. (Kloog et al., 2009)

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ELECTROMAGNETIC AND RADIOFREQUENCY EXPOSURES CAN REDUCE MELATONIN PRODUCTION IN THE PINEAL GLAND

In the 1990’s, the Swiss government conducted a series of studies of sleep qualitynear the Swiss national short wave radio transmission tower in Schwarzenburg. Thesestudies were initiated after the government received a petition stating that many resi-dents living near the transmitter were experiencing problems including nervousness,headache, sleep disturbance, and fatigue.

!O/2:()!PS!G%:1*!E1)).!T/7*:(<#$3)!8/*+!>O!)6.'7:()!#*!E3+8#(F)$<:(2;!E8/*F)(1#$%;!Figure 1: Sleep Disturbance by Proximity Zone in the Schwarzenburg Study.

(Cherry, 2002)

!#$%&'(! )*! +,-(.'(-/,0-(! '(123$,0-4$/! 5,'! 61((/!+$-3&'7208(! 23! 68492':(07&'%!9$34!Figure 2: Sleep Disturbance by Exposure Levels in the Schwarzenburg Study.

(Cherry, 2002)In these studies, a statistically significant increase in sleep disturbance was found

in residents living closer to the towers. Difficulty in maintaining sleep correlated withtransmission field strength, at exposure levels as low as 0.1 nanowatts/cm2. (Cherry,2002) (Abelin et al., 2005)

SECTION 3 – MICROWAVE RF EFFECTS ON MELATONIN SECRETION

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!#$%&'(! "*! 61((/! I$-3&'7208(! $0! /(,/1(! (;/,-(I! 3,! 2! -4,'3.92L(! '2I$,! -323$,0-!94$84!Figure 3: Reduction in Sleep Disturbance with Interruption of Tower Transmis-

sion in the Schwarzenburg Study. (Cherry, 2002)During an interval when the transmitter was turned off for three days, statisti-

cally significant reductions in sleep disturbance were found in both the high and thelow exposure groups (Figure 3). Note that Group C showed a reduction in sleep distur-bance with absence of the signal, despite the fact that signal strength in Zone Caveraged only 0.0004 μW/cm2 (4 μW/m2).

The Schwarzenburg transmission tower was shut down permanently in 1998. Ina final research project, sleep quality and salivary melatonin levels were measured in agroup of 54 community residents for an interval before and after the end of radiotransmission.

Baseline sleep quality was assessed by analysis of sleep diary records, andsubjects were stratified into two groups classified as either “poor” or “good” sleepers.Salivary melatonin samples were collected before breakfast, lunch, tea, dinner, andbefore bed. Subjects recorded morning tiredness and sleep quality, time of fallingasleep, and duration of sleep. Exposure levels were calculated for each subjects home.

During the baseline exposure period, scores of morning tiredness directly corre-lated with increased levels of exposure, and melatonin excretion levels were reduced bya factor of 0.90 for each mA/m of increase magnetic field exposure level. Peak mela-tonin excretion times were delayed by 4.4 minutes for every 1 mA/m increase in expo-sure level.

After shutdown of the transmitter, subjects’ morning fatigue scores improved by1.74 units for each 1 mA/m of reduced exposure, and melatonin excretion levelsincreased by a factor of 1.15 per mA/m of reduced exposure. (Altpeter et al., 2006)

The Schwarzenburg shutdown study’s findings were remarkable for two additi-onal reasons. First, there were no other significant levels of short wave radio exposurein the community at the time of the study. So this study provides a true eliminationand challenge test of RF exposure effects on a fairly large group of people in theirnormal environment. Such a study setting was difficult to arrange at that time, and


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would be even more difficult to achieve today, as the number of sources of RF exposurein our communities have increased markedly with the rollout of the wireless telecom-munications infrastructure.

Second, the stratification of the study group into “poor” and “good” sleepersallowed recognition of an important additional finding. Improvements in sleep qualityand melatonin secretion levels after transmitter shutdown were significantly greater in“poor” sleepers than they were in “good” sleepers. This evidence supports the hypo-thesis that some individuals may be more sensitive to the effects of microwave expo-sure, a condition that has been called “electrohypersensitivity” or EHS.

Multiple additional studies in a variety of settings have demonstrated an effect ofvarious forms of EMF/RF on melatonin physiology. Several comprehensive reviews ofthis research have been published in the last few years. (Cherry, 2002) (Davinipour andSobel, 2007) (Davanipour and Sobel, 2009)

Performing large long-term studies of RF effects on humans in a sleep laboratorysetting would be prohibitively difficult both logistically and financially. But severalrecent laboratory studies in animals have demonstrated suppression of melatonin byprolonged pulsed microwave RF exposures.

Kesari et al. exposed Wistar rats to 2.45 GHz mobile phone transmissions, 2hours daily for 45 days, at a calculated SAR of 0.9 W/Kg. Pineal melatonin levels weresignificantly reduced in exposed animals. (Kesari et al., 2011)

Kumar et al. repeated this experiment with 2.5 GHz exposures of 2 hours per dayfor 60 days, at a much lower exposure level (power density of 0.21 mW/cm2, calculatedSAR of 0.014 W/kg). Even at this low level of exposure (= 210 mW/cm2), serum mela-tonin levels were significantly reduced in exposed animals. (Kumar et al., 2011)

Figure 4: Serum melatonin levels in sham (black) and exposed (grey) Wistar ratsafter 2 hours daily exposure for 60 days to 2.45 GHz RF transmission at 0.21

milliwatts/cm2. (from Kumar et al., 2011)In another study, Kesari found significant reduction in pineal melatonin levels in

rats exposed to 2.45 GHz mobile phone transmissions, 2 hours daily for 45 days, at apower density of 0.21 mW/cm2 (calculated SAR of 0.014 W/kg). (Kesari et al., 2012)


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CONSEQUENCES OF REDUCTION OF MELATONIN LEVELS BY MICROWAVE RF EXPOSURE

Reduction of melatonin levels by exposure to radio transmissions could beexpected to cause sleep disturbance. Research findings like the Schwarzenburg studiesstrongly support this conclusion.

But melatonin has also been found to be protective against promotion of sometypes of cancer. If suppression of melatonin by “light at night” and night shift work canincrease risk of breast cancer (as discussed above), then suppression of melatonin byradio transmissions could also be expected to increase cancer risk. Recently publishedresearch studies strongly support this conclusion.

A study in Israel found women living within 350 meters of a cell phone tower tohave over 10 times greater risk of cancer than the community as a whole (p < 0.0001).(Wolf and Wolf, 2004)

A study of cancer patients in Germany found a 3.29 times greater risk of cancer(p < 0.01) in patients with residence closer than 400 meters to a cell pone tower. Risk ofbreast cancer was 3.4 times greater, and average age of diagnosis of breast cancer was19 years earlier. (Eger et al., 2004)

In a case/control study of cancer patients residing near a cell phone transmissiontower in Austria, those with external residential exposures of greater than 1000 μW/m2

(> 0.1 μW/cm2) had a a breast cancer risk that was 23 times higher (p = 0.0007) andbrain tumor risk was 121 times higher (p = 0.001) than controls. (Oberfeld, 2008)

A recent study from Brazil found a clearly elevated relative risk of cancer mor-tality at residential distances of 500 meters or less from cell phone transmission towers.(Dode et al., 2011)

Several recent published reviews discuss the multiple epidemiologic studies thathave shown an association between residential RF exposure from microwave transmis-sion towers and increased breast cancer risk. (Cherry, 2005) (Khurana et al., 2010)(Levitt and Lai, 2010) (Yakymenko et al., 2011) We will discuss this issue morethoroughly in Section 3.

RAISING THE LEVEL OF RADIOFREQUENCY TRANSMISSION IN RESIDENTIAL NEIGHBORHOODS CARRIES SIGNIFICANT RISKS

Unlike visible light, microwave radio transmissions penetrate walls and humanbodies. They are not easily blocked out by window blinds or eye shades. If microwaveradio waves can disrupt melatonin secretion in a portion of the population, then a signi-ficant increase in nocturnal RF transmission levels in a residential neighborhood wouldbe expected to produce an increase in sleep problems, and over the long run, anincrease in the incidence of breast and prostate cancer. The first evidence of such aneffect would be a significant increase in complaints of sleep disruption. It might requireseveral years of exposure for the increase in cancer incidence to reveal itself.

If we use complaints of sleep disruption as a marker for this effect, we cansuspect that the recent installation of MESH-networking smart meters in California andin other municipalities around the world has pushed many residential areas across athreshold, producing chronodysruption in a significantly increased portion of the popu-lation. The early evidence for this is that these smart meter rollouts have been followedby a dramatic increase in complaints of sleep difficulties received by physicians, bypublic utility commissions, and in postings on the internet.


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BIBLIOGRAPHY

Abelin T, Altpeter E, Roosli M. Sleep Disturbances in the Vicinity of the Short-WaveBroadcast Transmitter Schwarzenburg. Somnologie (2005); 9:203-209.


Bonde JP, Hansen J, Kolstad HA et al. Work at night and breast cancer - report onevidence-based options for preventive actions. Scand J Work Environ Health (2012);online first. doi:10.5271/sjweh.3282:1-11.

Cherry N. EMF/EMR Reduces Melatonin in Animals and People. (2002):1-14.http://www.neilcherry.com/documents.php

Cherry N. Electromagnetic Radiation causes cancer: the implications for breast cancer.(2005):1-39. http://www.neilcherry.com/documents.php

Davanipour Z, Sobel E. Long-term exposure to magnetic fields and the risks ofAlzheimer’s disease and breast cancer: Further biological research. Pathophysiology(2009); 16(2-3):149-156.

Davinipour Z, Sobel E. Magnetic Field Exposure: Melatonin Production; Alzheimer’sDisease; Breast Cancer. Bioinitiative Report (2007); Section 12:425-495.http://www.bioinitiative.org/

Dode AC, Leao MM, Tejo Fde A et al. Mortality by neoplasia and cellular telephonebase stations in the Belo Horizonte municipality, Minas Gerais state, Brazil. SciTotal Environ (2011); 409(19):3649-3665.

Eger H, Hagen K, Lucas B, Vogel P, Voit H. The Influence of Being Physically Near to aCell Phone Transmission Mast on the Incidence of Cancer. Umwelt Medizin Gesell-schaft (2004); 17(4):1-7.

Hill SM, Blask DE, Xiang S et al. Melatonin and associated signaling pathways thatcontrol normal breast epithelium and breast cancer. J Mammary Gland Biol Neoplasia(2011); 16(3):235-245.

Kesari KK, Kumar S, Behari J. 900-MHz microwave radiation promotes oxidation in ratbrain. Electromagn Biol Med (2011); 30(4):219-234.

Kesari KK, Kumar S, Behari J. Pathophysiology of microwave radiation: effect on ratbrain. Appl Biochem Biotechnol (2012); 166(2):379-388.


Kloog I, Haim A, Stevens RG, Barchana M, Portnov BA. Light at night co-distributeswith incident breast but not lung cancer in the female population of Israel. Chrono-biol Int (2008); 25(1):65-81.

Kloog I, Haim A, Stevens RG, Portnov BA. Global co-distribution of light at night(LAN) and cancers of prostate, colon, and lung in men. Chronobiol Int (2009);26(1):108-125.

Kloog I, Stevens RG, Haim A, Portnov BA. Nighttime light level co-distributes withbreast cancer incidence worldwide. Cancer Causes Control (2010); 21(12):2059-2068.

Kumar S, Kesari KK, Behari J. The therapeutic effect of a pulsed electromagnetic field onthe reproductive patterns of male Wistar rats exposed to a 2.45-GHz microwavefield. Clinics (Sao Paulo) (2011); 66(7):1237-1245.


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Oberfeld G. Environmental Epidemiological Study of Cancer Incidence in the Munici-palities of Hausmannstätten & Vasoldsberg (Austria). Provincial Government ofStyria, Department 8B, Provincial Public Health Office, Graz, Austria (2008): 1-10.

Reiter RJ, Rosales-Corral S, Coto-Montes A et al. The photoperiod, circadian regulationand chronodisruption: the requisite interplay between the suprachiasmatic nucleiand the pineal and gut melatonin. J Physiol Pharmacol (2011); 62(3):269-274.

Schernhammer ES, Berrino F, Krogh V et al. Urinary 6-sulfatoxymelatonin levels andrisk of breast cancer in postmenopausal women. J Natl Cancer Inst (2008);100(12):898-905.

Schernhammer ES, Hankinson SE. Urinary melatonin levels and postmenopausal breastcancer risk in the Nurses’ Health Study cohort. Cancer Epidemiol Biomarkers Prev(2009); 18(1):74-79.

Stevens RG. Working against our endogenous circadian clock: Breast cancer and electriclighting in the modern world. Mutat Res (2009); 680(1-2):106-108.

Wolf R, Wolf D. Increased Incidence of Cancer Near a Cell-Phone Transmitter Station.International Journal of Cancer Prevention (2004); 1(2):1-19.


Zawilska JB, Skene DJ, Arendt J. Physiology and pharmacology of melatonin in relationto biological rhythms. Pharmacol Rep (2009); 61(3):383-410.


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RADIOFREQUENCY EXPOSURE INCREASESOXIDATIVE STRESS AND DAMAGES DNA

Over the past 20 years, a great deal of research evidence has accrued whichdemonstrates that EMF and RF can alter cellular physiology.

INDUCTION OF STRESS PROTEINSWhen cells are stressed in a way that damages DNA in cells, an early response of

the cellular physiology is to increase the production of proteins involved in the repair ofthese structures. These repair proteins are called stress proteins or “heat shock”proteins (since early research models used heat to stress the cells). Increased produc-tion of these proteins are direct evidence of physiologic stress and damage to cell DNA,as they represent the effort of the cell to protect against and repair that damage.

The physiologic stressors that trigger this response stimulate specific regions onthe cell’s chromosome. These regions initiate the transcription of the stress responsegenes that encode for these repair proteins.

In the late 1990’s research demonstrated that EMF exposures can produce thesestress proteins. (Lin et al., 1997) (DiCarlo et al., 1998)

Further research demonstrated that EMF/RF stimulation promotes gene trans-cription at different promotion sites than those triggered by heat stress (Lin et al., 1998)(Lin et al., 1999), and that this promotion by EMF/RF can occur at power levels that arenot high enough to produce thermal changes in the cells. (DiCarlo et al., 1999) (Weis-brot et al., 2003) (Blank and Goodman, 2004) (Blank, 2007)

Subsequent research has shown that at DNA transcription sites activated by lowlevel EMF and RF exposure, higher levels of exposure can lead to single or doublestrand breakage of the DNA chain. (Blank and Goodman, 2009)

Current research confirms production of the stress protein response bymicrowave signals in the 900 MHz and 1800 MHz bands. (Cao et al., 2011) (Jiang et al.,2012) (Calabro et al., 2012)

DNA DAMAGEMany research studies performed in the last decade have demonstrated that

radio frequency radiation at nonthermal levels can produce fragmentation of DNA.In 2003, Ivancsits reported that intermittent low frequency EMF could cause

single and double strand breaks in DNA at magnetic flux densities as low as 35 micro-tesla, well below levels producing thermal effects. Effects were time and dose depen-dent. (Ivancsits et al., 2003)

This work was confirmed in 2004 in a study showing that 24 to 48 hour expo-sures to a 0.01 mT 60 hz magnetic field could produce single and double strand DNAcleavage, apoptosis, and necrosis of brain cells in rats. These effects could be blockedwith antoxidants, suggesting that free radicals played a role in the damage process. (Laiand Singh, 2004)

Subsequent research demonstrated that these effects also could be produced bynonthermal effects of radiofrequency microwave exposures—at power levels that werebelow the levels producing thermal effects—and that this nonthermal damage could beprevented by administration of antioxidant free radical scavengers. (Adlkofer, 2006)

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The results of in vitro studies on DNA damage from EMF/RF are variable, sincedifferent cell types have different sensitivities to these effects. (Schwarz et al., 2008)Several detailed reviews of these studies have been published in the last five years.These reviews document multiple studies showing production of DNA damage at lowpower densities, with more prolonged exposure times producing more significanteffects. (Lai, 2007) (Ruediger, 2009) (Phillips et al., 2009) (Levitt and Lai, 2010)

Current research continues to validate these findings. For example, Cam andSyhand found an increase in the production of single strand DNA breaks in hair rootcells following 15 to 30 minutes of mobile phone use. (Cam and Seyhan, 2012)

Figure 1: Comet Assay of DNA fragmentation in rat brains, produced byprolonged exposure to microwave RF. (Kesari et al., 2010a)

Kesari et. al. exposed Wistar rats to 2.45 GHz frequency at 0.34 mW/cm2 powerdensity (340 μW/cm2, whole body SAR ~ 0.11 W/Kg), 2 hours a day for 35 days, anddemonstrated increased double strand DNA breakage (p ≤ 0.0002) in brain tissue. Thiswas accompanied by decreased activity levels of glutathione peroxidase (p < 0.005) andsuperoxide dismutase (p < 0.006), and increased catalase activity (p < 0.006) suggestingthat the microwave exposure produced severe oxidative stress. (Kesari et al., 2010a)

Kumar et. al. exposed Wistar rats to 50 GHz continuous source microwave trans-mission, 2 hours a day for 45 days, with a power density of 0.86 μW/cm2 (calculatedSAR 8.0 x 10-4 W/kg). Other rats were exposed to 10 GHz, 2 hours a day for 45 days,power density 0.214 mW/cm2 (214 μW/cm2, SAR 0.014 W/kg). Both forms of exposureproduced significantly altered levels of reactive oxygen species, antioxidant enzymeactivity, and blood cell micronuclei formation, demonstrating the production of oxida-tive stress with genotoxic effects. (Kumar et al., 2010)

RF EXPOSURE PRODUCES OXIDATIVE STRESSIt is a truism among apologists for the telecommunications industry that

microwave radiofrequency transmissions cannot possibly cause cancer, because theenergy of a photon of this wavelength is not powerful enough to directly break an ionic

SECTION 4 – OXIDATIVE STRESS, DNA DAMAGE, CANCER AND INFERTILITY

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bond the way an xray can, and therefor could not possibly cause mutations in DNA.Such an argument sounds like good physics, but it isn’t good biology. Ionizing radia-tion is only one way to cause the mutations in DNA that can produce cancer.

Chronic inflammation can cause cancer. Cigarette smoke can cause cancer.Toxins and autoimmune disease can cause cancer. One common pathway shared bythese causes is that they produce an inflammatory response in the body that increasesthe activity of free radicals (reactive oxygen species). These free radicals produce oxida-tive damage in the tissues.

This oxidative activity is the tool that our bodies use to destroy foreign bacteria,which can be completely broken up—DNA and all—and digested by our immunesystem. Free radicals are an important defensive weapon for our bodies, but an excessof oxidative activity can lead to damage of our own tissues. Such excesses have beenassociated with many chronic problems including autoimmune disease, heart disease,and some forms of cancer. Every week another article is published suggesting thattaking antioxidants may be protective against some of these problems.

The mechanisms through which EMF/RF increase oxidative stress in livingtissues have not been clearly elucidated, although some ideas have been proposed.(Liboff, 2010) (Georgiou, 2010)

But in the last decade, the scientific research clearly established that EMF and RFexposure cause an increase in reactive oxygen species in living tissues, leading tooxidant damage of DNA. (Shiroff, 2008)

Figure 2: Depletion of antioxidants in RF-exposed rat brains, after exposure to 2.45GHz, 2 h a day for 35 days at 0.34 mW/cm2 power density, 2.45 GHz frequency.

(Kesari et al., 2010a)Studies cited above document that microwave RF exposures at very low power

densities produce oxidant stress accompanied by DNA damage. (Kesari et al., 2010a)(Kumar et al., 2010)

Other recently published studies also show that RF exposure can increaseoxidant stress and tissue damage in brain tissue (Maaroufi et al., 2011) (Avci et al.,2012), liver tissue (Guler et al., 2012), white blood cells (Lu et al., 2012), and human sali-vary glands (Hamzany et al., 2012).


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SUPPRESSION OF MELATONIN SECRETION COMPOUNDS THE PROBLEM.The problems caused by increased oxidative stress from EMF/RF are

compounded by the fact that EMF/RF can also suppress melatonin secretion by thepineal gland, since melatonin is one of the most potent antioxidant molecules producedin the body.

Figure 3: Suppression of melatonin secretion by 2.45 GHz RF,2 hours a day for 45 days at 0.21 mW/cm2. (Kesari et al., 2012)

In recently published study, Kesari et. al. exposed Wistar rats to 2.45 GHzmicrowave radio transmission, 2 hours a day for 45 days, at a power density of 0.21mW/cm2 (210 μW/cm2, whole body SAR ~ 0.14 W/kg). Pineal melatonin was signifi-cantly decreased in the exposed group. (Kesari et al., 2012)

Multiple studies have documented that exposure to microwave RF can reducemelatonin levels in animals and in people. (see Section 3).

CONSEQUENCES OF OXIDATIVE DAMAGE TO DNAEVIDENCE FOR CANCER

When DNA is damaged, the body attempts to repair it. Errors in DNA codingsequence produced during the repair process can produce mutations. And it is hypo-thesized that such mutations in DNA are a major cause of cancer.

So if radio frequency (RF) and microwave (MF) exposure increase oxidativedamage to DNA, we would expect to see evidence that chronic RF exposure increasedthe rate of some forms of cancer. A significant body of epidemiologic research in avariety of exposure settings suggests that this is indeed the case.

Electronics techniciansIn the 1980’s, Milham published evidence of increased leukemia in electrical

workers (Milham, 1985b)Another study of workers in the electronics industry found an increased risk of

brain tumor associated with exposure to microwave radio transmission, with a highlysignificant increase in risk in those with more than 20 years of exposure. (Thomas et al.,1987)


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A case/control study of brain cancer deaths in Maryland found a threefoldgreater brain cancer incidence in electrical or electronic engineers and technicians,compared to the reference population. (Lin et al., 1985)

A study of leukemia rates in different occupational groups in the U.S. Navyshowed increased leukemia risk in electrician’s mates. (Garland et al., 1990)

Figure 4: Mortality (1950–1974) in U.S. Navy Korean War Veterans, stratified by in-service levels of occupational radar exposure. (Cherry, 2002a, after Robinette, 1980)

A study performed for the U.S. military published data comparing a cohort of20,000 Korean War veterans with higher occupational exposure levels to RF/MW expo-sure to 208,000 Korean war veterans with minimal occupational exposure during theirservice years. Mortality statistics were reviewed for the interval between 1950 and 1974.(Robinette et al., 1980) This data shows that the group with the highest rated occupa-tional exposure level (aviation electronic technicians) had a significantly higher totaldeath rate during the study period, and a higher death rate from disease, from malig-nancy, and from lymphatic and hematopoetic malignancies. (Goldsmith, 1997a)

A study of Polish career military personnel from 1971 – 1985 showed double therisk of cancer in personnel with occupational exposure to RF/MW transmission, ascompared other personnel. The exposed cohort had higher morbidity rates for GIcancers (Observed versus Expected Ratio = 3.19 – 3.24), brain tumors (OER = 1.91), andhematopoetic malignancy (OER = 6.31), including chronic myelocytic leukemia (OER =13.9), acute myeloblastic leukemia (OER = 8.62), and non-Hodgkin’s lymphoma (OER =5.82). (Szmigielski, 1996)

Radio OperatorsIncreased rates of acute myeloid leukemia and of other lymphatic malignancies

have been found in large population based studies of amateur radio operators (Milham,1985a) (Milham, 1988a) (Milham, 1988b).


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Figure 5: Analysis of leukemia deaths in male members of the American RadioRelay League resident in Washington and California, 1971 – 1983. (Milham, 1985a)

Another study of female radio and telegraph operators in Norway found anincreased incidence of breast cancer in this group as compared to the standardized inci-dence rate in the female population of that country. (Tynes et al., 1996)

Police radar operatorsTwo studies have shown increased rates of testicular cancer (Davis and Mostofi,

1993), and of testicular cancer and melanoma (Finkelstein, 1998) in police officers withoccupational exposure to handheld radar.

Airline pilotsAirline pilots have significant occupational exposure to RF/MF (radio frequency

and microwave frequency) transmissions.A study of U.S. Air Force personnel showed an increased risk of brain tumors

associated with increasing rank, and associated with estimated exposures to bothmicrowave radio and low frequency radio transmissions. No increased risk associatedwith exposure to ionizing radiation was found in this study population. (Grayson, 1996)

A study of commercial airline pilots in Iceland found an increased risk of malig-nant melanoma. (Rafnsson et al., 2000) Another study with Danish pilots showedincreased risk of total cancer, melanoma, other skin cancers, and acute myeloidleukemia in commercial airline cockpit crews. (Gundestrup and Storm, 1999) Neither ofthese studies specifically controlled for RF/MF exposures as compared to other expo-sures (cosmic rays, tropical sun on the beach, etc.) incurred by flying personnel.

However, an extensive study of German commercial airlines crews (including6,017 cockpit and 20,757 cabin crew members) showed an increased brain cancer risk forcockpit crew and an increased all cancer risk for cockpit crew with more than 30 yearsemployment compared to those with under 10 years of employment. Notably, theseincreased risk were not found in cabin crew members, who share equal exposure tocosmic rays and tropical beaches, but are farther from the radios. (Zeeb et al., 2010)

U.S. Embassy Moscow 1953 – 1976From the 1950’s to the mid-1970’s the U.S. Embassy in Moscow was exposed to a


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constant low intensity radar signal, as a form of harassment by the Russian government.The exposure level on the outside of the west facade of the building was measured at 5microwatts/cm2, and was present for 9 hours a day. Since the wall and windows atte-nuated the signal, inside exposure levels were likely to be in the range of 0.02 to 0.1μW/cm2.

The State Department contracted an epidemiologic analysis potential healtheffects on exposed personnel and their dependents, which was performed by A.M. Lili-enfeld M.D., and epidemiologist at John’s Hopkins University. This report waspublished including all of the tabulated raw data. (Lilienfeld AM, 1979)

The report as finally released stated as a conclusion that personnel “suffered noill effects” from the microwave exposure. However, the published conclusions differedfrom the original conclusions written by Dr. Lilienfeld, and evidence suggests that thefinal conclusions were “whitewashed”. (Goldsmith, 1997b) One can presume that thismight have been done to avoid embarrassment of the federal government, since anyharm, if produced, would have been produced at levels of exposure orders of magni-tude less than those exposure levels permitted by United States FCC guidelines.

A hematologic study performed on employees at the Moscow embassy wassubmitted to the U.S. government in October, 1976. This study showed significantabnormalities in hematologic parameters in this group, in comparison with studies offoreign service workers in the United States. (Goldsmith, 1997a)

The published data from the Lilienfield study of Moscow embassy workers andtheir dependents has subsequently been analyzed by other epidemiologists and foundto show a statistically significant increase in total adult and childhood cancers, in breastcancer, and in childhood leukemia. (Goldsmith, 1995) (Cherry, 2002a)

Residential exposure to Radio/TV Transmission towersBy the late 1990’s, a significant body of epidemiologic literature had accumulated

that demonstrated an association between exposure to radar and RF radiation and theoccurrence of certain types of cancer.

Evidence for association between radio transmission tower exposures and adultand/or childhood leukemia has been reported in studies from Hawaii (Maskarinec etal., 1994) and Australia (Hocking et al., 1996).

A study from England shows an increased risk of adult leukemia in those resi-ding within two kilometers of the transmission tower, and decreased risk of leukemia,skin cancer, and bladder cancer with increased distance of residence from the tower.(Dolk et al., 1997b) A follow-up study involving multiple other sites in England alsoshowed a statistically significant decline in risk of adult leukemia with increasingdistance of residence from transmission sites. (Dolk et al., 1997a) (Hocking et al., 1998)

A study in Rome evaluated the incidence of adult and childhood leukemia as afunction of residential proximity to the Vatican Radio transmission tower. Pediatricleukemia cases were more common than expected at less than 6 kilometers from thetower, and significantly elevated in adult men living within 2 km of the tower. Adultmale leukemia mortality and childhood leukemia rates showed a significant decreasewith increasing distance between tower and residence. (Michelozzi et al., 2002)

A study of cancer incidence in proximity to the Sutro radio/TV tower in SanFrancisco also showed a strong correlation of exposure and incidence of several types ofchildhood cancer. (Cherry, 2002b) This study was notable for its rigor in analyzing theactual exposure levels around the tower in relation to the data set. Power density/


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exposure levels around UHF and VHF broadcasting antennae are not distributed in asimple and symmetrical regression (“with the square of the distance”). Transmissionexposure levels form a series of peaks and valleys around these antennae, and theantennae can be arranged to focus more power in one direction than another, aiming astronger signal at the target audience in a population center. Studies that fail to takethis distribution into account and assume that exposure is in direct ratio to distance willmix higher and lower exposure groups together, diluting the power of the study andunderestimating true risk in relation to exposure.

In another paper, Dr. Cherry analyzes this issue in detail, and uses his more rigo-rous approach to review and refine the analysis of data from many of the earlier studieson health effects of radio/TV broadcast towers. His analysis strengthens the evidencefor increased cancer risk from these exposures. (Cherry, 2002a)

A large population case/control study in south Korea looked at 1928 leukemiapatients and 956 brain cancer patients under 15 years of age who were diagnosedbetween 1993 and 1999 at 14 large hospitals in Korea. These cases were matched with3082 age matched patients who received respiratory disease diagnoses (primarilyasthma) at the same hospitals during the study period. Case and control exposurelevels were calculated for 31 transmitters in South Korea that had a transmission powergreater than 20 kW, using a mathematical model that was correlated with field testing.Children residing within 2 kilometers of a transmission tower had a significantlyincreased risk of leukemia as compared to children with residence greater than 20 kmfrom the tower (OR 2.15, 95% CI = 1.00 to 4.67). (Ha et al., 2007)

Residential Exposure to Cell Phone Tower (Base Station) TransmissionsWith the dramatic rollout of commercial cell phone service in the 1990’s, large

segments of the population became exposed to significantly higher levels of microwaveRF exposure due to the installation of cell phone towers in urban areas. Several recentpapers have reviewed the significant evidence for ill effects from these urban exposures.(Khurana et al., 2010) (Yakymenko et al., 2011) (Kumar, 2010)

Netanyu, IsraelWolf and Wolf studied rates of cancer incidence during the second year of opera-

tion of a 1500 watt 850 MHz cell phone tower in Netanya, Israel. The study group wascomposed of 622 individuals who had lived in area A, within 350 meters of the tower,for the previous 3 to 7 years. A control group of 1,222 individuals living in an outlyingarea B was also studied.

During the study year, 8 cases of cancer occurred in the study group, and 2 casesoccurred in the control group. The cancer rate for the entire town was 31 cases per10,000. Relative cancer rates for females was 10.5 for the study group, 0.6 for the controlgroup, and 1.0 for the town as a whole (P < 0.0001).

Signal power densities of the tower’s transmissions in the homes of the cancercases ranged from 0.3 – 0.5 μW/cm2. [note that FCC limits are 600 – 1000 μW/cm2.]

In the year following the close of the study, another 8 new cases of canceroccurred in area A, and another 2 cases occurred in area B. (Wolf and Wolf, 2004)

Naila, GermanyA cell phone transmission tower was placed in the town of Naila, Germany, in

1993. Eger, Hagen, et. al. reviewed the medical health records from 1994 to 2004 foraround 1000 residents of the municipality (roughly 90% of the population). All


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included patients had been living at the same address during the entire 10 years ofobservation.

Over the course of the entire study period, patients living in an inner area within400 meter of the transmission tower had 2.27 times the relative risk of cancer incidence,compared to patients living more than 400 meters from the tower (p < 0.05). Cancerpatients in the inner residential area also developed cancer an average of 8.5 yearsearlier in life than did cancer patients residing in the more distant area.

For the years 1999 to 2004 (after 5 years of tower operation) the relative risk ofcancer incidence in residents less then 400 meters from the tower increased to 3.29 (p< 0.01). Relative risk of breast cancer was 3.4 in the inner area, where average age ofdiagnosis was 50.8 years, compared to 69.9 years in the outer area. (Eger et al., 2004)

Hausmannstätten and Vasoldsberg, AustriaOberfeld performed a case/control study of cancer patients in the municipalities

of Hausmannstätten and Vasoldsberg, Austria. All subjects had resided within 1,200meters of an analogue cell phone tower that operated between 1984 and 1997 in themunicipalities.

Figure 6: Odds ratio of cancer incidence, stratified by exposure levels(exterior to dwelling) in μW/m2. (Oberfeld, 2008)

Residential outdoor exposure levels were measured, and three different case/control groups were assessed, for case exposure levels outside the residence of 10 – 100μW/m2 (= 0.001 – 0.01 μW/cm2)), 100 – 1000 μW/m2 (= 0.01 – 0.1 μW/cm2), and greaterthan 1000 μW/m2 (> 0.1 μW/cm2). respectively. The reference exposure level for thecontrol group was less than 10 μw/m2 (= 0.001 μW/cm2). [Note that FCC thermal safetylimits are 6,000,000 to 10,000,000 μW/m2.]

Cancer risk for all cancers was significantly elevated for all three elevated expo-sure categories, and was 5 to 8 times higher in the >1000 μW/m2 (> 0.1 μW/cm2) cate-


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gory (p=0.001). In this highest risk group, breast cancer risk was 23 times higher (p =0.0007) and brain tumor risk was 121 times higher (p = 0.001). (Oberfeld, 2008)

Belo Horizonte, BrazilDode et. al. studied deaths from cancer in the city of Belo Horizonte in southern

Brazil from 1996 to 2006. This city of over 2 million inhabitants was rated by the UnitedNations in 2007 as having the best quality of life in Latin America. The researchers usedthe database of deaths by neoplasm of the City Health Department, the database of cellphone base station sites from the Brazilian Telecommunications Agency, and a databaseof the city census and demographics. Exposure duration was calculated from the dateof installation of the first antenna to which the individual had been exposed, and resi-dential distance from that exposure was calculated in 100 meter increments.

Figure 7: Cancer death rate as function of residential proximity to cell phone trans-mission towers in meters. Horizontal line = null hypothesis. (Dode et al., 2011)

The highest concentration of base stations was in the south central part of thecity. In 2008, environmental monitoring of microwave radiation was performed at 400sites, measuring frequency bands between 800 MHz and 1800 MHz. Signal intensityaveraged 7.32 V/m (~ 14.2 μW/cm2), with a range from 0.4 to 12.4 V/m (~ 0.04 to 40.7μW/cm2). These intensity levels are well below the ICNIRP guidelines for microwaveradiation exposure, which are based on protection against thermal effects.

Analysis of the data showed that cancer mortality rates were higher near the cellphone transmission towers. Within the range of 100 meters of a tower, the mortalityrate was 43.42 persons per 10,000 (compared to a rate of 32.12 per 10,000 for the city as awhole), with a relative risk of 1.35.

The mortality rate reduced in proportion to residential distance from cell phonetower. Relative risk of cancer mortality was clearly elevated at residential distances of500 meters or less from a cell transmission tower (base station, or BS) as illustrated inFigure 7. (Dode et al., 2011)


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TaiwanLi et. al. performed a case/control study of 2606 children age 15 or less who were

diagnosed with a neoplasm in Taiwan between 2003 and 2007. Each case was matchedwith 30 controls. Residential exposure of cases and controls was calculated based onthe annual power density in watt-years per kilometer squared for each of the 367 towns-hips in Taiwan, averaged out for the 5 year period prior to diagnosis in the townshipwhere the subject resided at time of diagnosis.

This study is notable for the large number of cases and controls, which shouldincrease the power of the study. On the other hand, if elevated microwave exposure isassociated with cancer risk, assuming that power density of cell phone tower transmis-sions is constant throughout each township would serve to minimize the effects ofhigher exposure levels closer to the towers, minimizing the distinction between higherand lower cohorts, and diluting the power of the study.

Case/control analyses were performed for “all cancer types”, for leukemia, andfor brain neoplasm. Odds ratio for cases of “all cancer types” with calculated exposuregreater than median exposure value of controls were significantly elevated at 1.13 (95%CI = 1.01 to 1.28). Odds ratio for cases of leukemia with calculated exposure greaterthan median exposure value of controls were elevated at 1.23 (95% CI = 0.99 to 1.52).Odds ratio for cases of brain neoplasm with calculated exposure greater than medianexposure value of controls were slightly elevated at 1.14 (95% CI = 0.83 to 1.55). (Li etal., 2012)

EVIDENCE FOR IMPAIRMENT OF FERTILITYToxic exposures that damage DNA can cause cancer. They can also cause

damage to the production of healthy eggs and sperm, leading to infertility. Ifmicrowave RF exposure causes oxidative damage to DNA, this should lead to measu-rable alterations in function of reproductive function and fertility. Current research isbeginning to prove the presence of this effect.

Laboratory studies in insectsIn 2004, Panagopoulos et. al. demonstrated that exposure to a modulated GSM

900 MHz cell phone signal for 6 continuous minutes daily for two days decreased thefertility of both male and female fruit flies (Drosophila melanogaster). Exposure powerdensity was ~ 0.436 milliwatts/cm2 (= 436 μW/cm2). (Panagopoulos et al., 2004)

In a later study, Panagopoulos et. al. exposed Drosophila fruit flies to a cellphone transmitting GSM 900 MHz at 0.40 mW/cm2 (= 400 μW/cm2—Group 1) or GSM900 MHz at 0.29 mW/cm2 (= 290 μW/cm2—Group 2), or DCS 1800 MHz at 0.29 mW/cm2 (= 290 μW/cm2—Group 3). Transmission exposures were 6 consecutive minutesper day for six days. The exposure induced fragmented DNA during oogenesis. Celldeath scores in the ovaries of female flies were 63% in Group 1, 45% in Group 2, and39% in Group 3, as compared to 7.8% in the sham and control groups. (Panagopoulos etal., 2007)

Subsequent research exposed Drosophila fruit flies to GSM 900 MHz or DCS1800 MHz signals for signal durations of 1 to 21 minutes a day for five consecutive days,at a power density of 10 μW/cm2. Impairment of fertility increased linearly with dura-tion of exposure (see figure 2). Even at 1 minute of exposure a day, fertility was signifi-cantly decreased in exposed versus sham exposure specimens (p < 0.00001). (Panago-poulos and Margaritis, 2010)


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Figure 8: Decreased fertility of fruit flies at exposure level of 10 μW/cm2.(Panagopoulos and Margaritis, 2010)

In another study using a GSM 900 MHz cell phone signal at 0.35 mW/cm2 (= 350μW/cm2), six minutes of daily exposure was divided into one, two, or three minutesegments, spaced 10 minutes apart. This was compared with one 6 minute constantexposure and with two 3 minute exposures spaced 6 hours apart. DNA damage andcell death in the intermittent exposures sequenced 10 minutes apart was essentially thesame as with the constant 6 minute exposure (p > 0.92), and markedly higher than inthe sham group (p < 10-8). The group with divided exposures 6 hours apart had less celldeath than the more frequently exposed group, but still showed significantly higherinfertility than the control group (p < 0.002). (Chavdoula et al., 2010)

In yet another study, the Panagopoulos group evaluated influence of GSM 900MHz and 1800 MHz cell phone transmissions on Drosophila fertility using exposures of6 minutes per day for 6 days, at exposure distances varying from 0 to 100 cm. Theywere able to demonstrate an adverse effect on fertility for all exposures at all powerdensities greater than or equal to 1 μW/cm2. (Panagopoulos et al., 2010)

Recently Panagopoulos published another study demonstrating that exposure toa GSM 900 MHz modulated cell phone transmissions at ~0.35 mW/cm2 (= 350 μW/cm2)for 6 minutes during ovarian development can seriously retard ovarian maturation andreduce final size of ovaries in Drosophila fruit flies. (Panagopoulos, 2012)

Laboratory studies in animalsMagras and Xenos placed caged mice at various locations in an antenna park in

Thessaloniki, Greece, at locations with RF power densities ranging from 168 nW/cm2 (=0.168 μW/cm2) to 1053 nW/cm2 (= 1.053 μW/cm2). The mice lived in these locations forsix months, during which time they were mated repeatedly. Numbers of newborns perlitter decreased progressively, and ended with complete infertility by the fifth matingcycle. This infertility was not reversible with removal to an unexposed laboratory envi-ronment. (Magras and Xenos, 1997)

Meo et. al. exposed Wistar rats to cell phone transmissions for either 30 or 60


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minutes a day for 3 months, and then measured serum testosterone levels. Testosteronelevels decreased with increased duration of exposure, and the difference in testosteronelevel between subjects and controls was statistically significant in the 60 minutes perday group (p < 0.02) (Meo et al., 2010)

Otitoloju et. al. evaluated sperm head morphology in laboratory rats that wereexposed to cell tower transmissions at two locations with mean RF exposure levels of489 ± 43 mV/m (~ 0.6 μW/cm2) and 625 ± 25 mV/m (~ 0.10 μW/cm2). A control groupwas held in a laboratory with RF exposure levels of 59 ± 17 mV/m (~ 0.001 μW/cm2).After six months of exposure, exposed rats showed mean sperm head abnormalities of40% and 46%, versus 2% in control animals. (Otitoloju et al., 2010)

Kesari and Behari exposed male Wistar rats to 50 GHz continuous microwaveradiation at a power density of 0.86 μW/cm2 (calculated SAR 8 x 10-4 W/kg), 2 hours aday for 45 days. Sperm cells showed significant reductions of glutathione peroxidaseand superoxide dismutase activity (p ≤ 0.05) and increased catalase activity (p < 0.02),consistent with a significant increase in oxidative stress. Histone kinase activity wasalso increased (p < 0.016), and and significantly increased apoptosis (programmed celldeath) and alteration in phases of sperm development were also present. (Kesari andBehari, 2010)

In a similar study, Kesari et. al. confirmed a significant increase in cell deaththrough apoptosis, reduced sperm count, and reduced protein kinase C activity in maleWistar rats exposed to cell phone transmissions 2 hours daily for 35 days. Exposurepower densities ranged from 0.1 – 2.0 mW/cm2 (= 100 – 2000 μW/cm2, calculated SAR0.9 W/kg. (Kesari et al., 2010b)

In 2011 and 2012 Kumar and Kesari published four additional papers documen-ting the adverse effects of 10 GHz microwave exposure (2 hours daily for 45 days atpower density of 0.21 mW/cm2 (= 210 μW/cm2, SAR 0.014 W/kg) on fertility in maleWistar rats. These studies document significant levels of pathological change includingincreases in reactive oxygen species, increased apoptosis (cell death) in sperm cells andaltered sperm cell cycle (Kumar et al., 2011), increased free radical formation, decreasedactivity of glutathione peroxidase and superoxide dismutase, increased activity of cata-lase and malondialdehyde, decreased histone kinase (Kesari et al., 2011), reduced testos-terone levels, shrinkage of seminiferous tubules and testicular size, distortion of spermstructure, decreased number and weight of progeny (Kesari and Behari, 2012), forma-tion of micronuclei bodies in lymphocytes, DNA strand breakage, altered levels ofhistone kinase, altered percentage of spermatogenic phases, and (again) reduced testos-terone levels and shrinkage of seminiferous tubules. (Kumar et al., 2012)

In 2012, Atasoy et. al. published a study of rats exposed to a WiFi router(802.11.g, 2.437 GHz) for 20 weeks, 24 hours a day. Histological and immunohistoche-mical examinations of the rats’ testes showed evidence of DNA damage compared tocontrols (p < 0.05) and decreased activity levels of antioxidants (catalase and glutat-hione peroxidase, p < 0.05). (Atasoy et al., 2012)

Other animal studiesExperimental laboratory evidence clearly demonstrates that microwave RF radia-

tion can adversely effect reproduction in insects and animals. Some evidence tosupport this is also available from studies of animals exposed to RF in their naturalenvironment.


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Figure 9: Impaired fertility in white storks nesting near cell phone towers.(Balmori, 2005)

Balmori studied a white stork population that was nesting near a cluster of cellphone towers in in Valladolid, Spain. Power densities at ground level ranged from 10μW/cm2 at 50 meters from the towers to 1 μW/cm2 at 100 meters distance and a tenthsof a μW/cm2 at 150 to 200 meters distance. Total breeding productivity was signifi-cantly reduced at nests closer than 200 meters, compared to nests farther than 300meters from the towers. (Balmori, 2005)

Balmori performed bird counts at 30 locations during 40 visits to Valladolid,Spain, over the interval between October 2002 and May 2006, and measured mean elec-tric field strength at each counting site. Bird population density declined significantlyover the observation period (p = 0.0037), and population density was significantly lowerin areas with higher electric field strength (p = 0.0001). (Balmori and Hallberg, 2007)

Balmori also studied reproductive success of common frogs (Rana temporaria) ata breeding site 140 meters from a cluster of cell phone towers. Electric field intensitiesmeasured at 1.8 to 3.5 V/m (~0.9 to 3.2 μW/cm2). Some eggs were in enclosures thatwere permeable to microwave radiation, and others were shielded in grounded Faradaycages. Exposed eggs showed asynchronous growth with varying tadpole size and a90% mortality rate, while shielded eggs developed synchronously with a 4.2% mortalityrate. (Balmori, 2010a)

Much more work needs to be done on in vivo studies of the effects of microwave cellular transmissions on animals and plants. Two reviews of the existing research havebeen published. (Balmori, 2009) (Balmori, 2010b)

Human studiesHuman sperm counts have been declining for decades. In 1992 Carlsen et. al.

published a meta-review of 61 studies published between 1938 and 1991, with 14,947subjects. They found a decreased in mean sperm count from 113 million/ml to 66million/ml (p < 0.0001) between 1940 and 1990, with a decrease in seminal volume from


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3.40 ml to 2.75 ml (p = 0.027). Additionally, the percentage of men with sperm counts< 20 million/ml increased over this time period, while the percentage of men withsperm counts > 100 million/ml decreased. The incidence of testicular cancer increasedbetween two and fourfold during this interval. (Carlsen et al., 1992)

Carlsen’s analysis produced controversy initially. But subsequent analysis hasshown that their results were essentially correct. Analytic approaches to their data setthat refined the analysis to adjust for bias of various kinds have continued to supportthe validity of their conclusions. (Swan and Elkin, 1999)

In another meta-analysis, Swan et. al. looked at 54 of the most robust studies inthe Carlsen data set, and at 47 additional studies, covering studies from 28 countriesover a total time interval from 1934 to 1996. They found a rate of decrease in spermcounts of 0.80 million/ml per year in North America and 3.13 million/ml per year inEurope/Australia. (Swan et al., 2000)

And more recent studies have shown that this downward trend in sperm countsis continuing. Jorgensen et. al. found decreasing levels in sperm concentration, totalsperm count, and percentage of morphologically normal sperm in Finnish men born in1987 versus 1982 – 83 versus 1979 – 1981. (Jorgensen et al., 2011) Sperm counts in NewZealand sperm donors decreased 50% between 1987 and 2007, an average of 2.5% peryear. (Shine et al., 2008)

In the early 1990’s, it was hypothesized that this decrease in sperm counts andincrease in testicular pathology might be due to exposure of male embryos to exoge-nous estrogens (DES, pesticide residues, plasticizers like Bisphenol A, etc.) early indevelopment. (Sharpe and Skakkebaek, 1993) (Carlsen et al., 1995) (Irvine, 1997)

In 1994, Abell et. al. described higher sperm counts in members of a Danishorganic farmer’s association, as compared with Danish men who had occupationalexposures to xenoestrogens. (Abell et al., 1994) Jensen et. al. found a 43.1% highersperm concentration (p = 0.033) in 55 members of Danish organic foods associationswho ate at least 25% organic foods, as compared with 141 normal controls. (Jensen et al.,1996)

Multiple studies in animal models have shown that in utero exposures to estro-genic chemicals can alter testicular health and function. Regional variations in spermcount and testicular cancer rates suggest the possibility of environmental influences. Arecent paper by Nordkap et. al. reviews current perspectives on this subject. (Nordkapet al., 2012)

On the other hand, estrogenic xenobiotic chemicals have been present in the foodchain since the 1950’s. Adverse clinical effects of these exposures have been discussedsince the early 1960’s. (Randolph, 1962) Unless the human body burden of these chemi-cals has continued to significantly increase over the last 50 years, we would expect theinfluence of this effect on sperm counts to plateau.

But sperm counts have not plateaued. They have continue to decrease throug-hout the developed world. A recent study of 26,609 french partners of totally infertilewomen seeking in vitro fertilization found a 32.2% decrease in sperm concentrationbetween 1989 and 2005, with projected sperm counts for a 35 year old man droppingfrom 73.6 million/ml to 49.9 million/ml. (Rolland et al., 2012)

This continued trend should be a cause for significant alarm. The World HealthOrganization defines sperm counts above 20 million/ml as normal. But studies haveshown that couples take longer to get pregnant at sperm counts below 40 to 55 million/


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ml. (Bonde et al., 1998) (Guzick et al., 2001) (Slama et al., 2002) In Israel, a recent studyof sperm donors showed that over the last 10 to 15 years the average sperm count hasdropped from 106 million/ml to 68 million/ml, an average decrease of 2.5 million/ml(0.8%) per year. 15 years ago, 66% of sperm donations were of acceptable quality; usingthe same criteria, at the current time only 18% of donations would be of acceptablequality. (Haimov-Kochman et al., 2012)

As discussed above, studies in insects and animals have demonstrated thatmicrowave radio exposure at remarkably low power densities can have an adverseeffect on male fertility. With the rollout of cellular and WiFi infrastructure, exposure tothese radio frequencies has increased dramatically in the last 20 years. Would it bereasonable to ask if such exposures have played a role in the continued decrease in malefertility that has occurred during this time period? The result of several recent studiessuggests that the answer to this question is “Yes”.

Erogul et. al. split human sperm samples and exposed one part to signal from a900 MHz cell phone. They found statistically significant decreases in motility of spermin the exposed samples. (Erogul et al., 2006)

Fejes et. al. measured semen quality in a cohort of 371 subjects where confoun-ding factors had been excluded, and found a significant decrease in sperm motility (p< 0.01) in individuals with talk time > 60 minutes/day versus talk time < 15 minutes/D.Decreased sperm motility also correlated with increased duration of cell phoneownership in months. (Fejes et al., 2005)

Figure 10: Decrease in sperm count (5), motility (6), viability (7) and normalmorphology (8) with increased cell phone talk time. (Agarwal, 2008)

Agarwal et. al. studied semen quality in 361 subjects, divided into four groupsbased on daily cell phone usage (no use, < 2 hours/day, 2 to 4 h/D, > 4 h/D). Theyfound that sperm count, motility, viability, and percent normal morphology all decre-ased with increased cell phone use. (Agarwal et al., 2008)


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Figure 11: Sperm exposed in vitro to 1.8 GHz (SAR = 27.5 W/kg) for 16 hours @21ºC (isothermal conditions). (De Iuliis et al., 2009)

De Iuliis et. al. exposed human sperm to 1.8 GHz microwave radio transmis-sions. Statistically significant decreases in sperm motility and vitality were demonstrateat exposure levels as low as 1.0 W/kg (p < 0.01). This study also found an increase inreactive oxygen species, oxidative damage to DNA, and DNA fragmentation, that wasnot dependent on thermal effects. (De Iuliis et al., 2009)

Figure 12: A) Production of ROS with increasing levels of microwave RF .B) Production of ROS with increasing levels of temperature.

(De Iuliis et al., 2009)


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Figure 13: Sperm damage from exposure to laptop computer WiFi transmission.(Avendano et al., 2011).

Another recent study the effects of exposing motile sperm to 4 hours of WiFitransmission at a position 3 cm beneath a laptop computer, at power densities between0.45 and 1.05 μW/cm2. Temperature was maintained at a constant 25ºC. Exposed speci-mens showed a statistically significant decrease in sperm progressive motility, and asignificant increase in non-motile sperm and in sperm DNA fragmentation. (Avendanoet al., 2011)

The fact that multiple recent studies have demonstrated the ability of microwaveRF exposure to cause nonthermal damage sperm function and sperm DNA with shortexposure times and quite low exposure levels—the FCC exposure limit is 1000 μW/cm2—should be a source of grave concern. The presence of constantly transmittingWiFi networks in homes and schools may be much less innocuous than is generallysupposed.


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CURRENT RESEARCH ONCELL PHONE USE AND BRAIN TUMOR RISK

INTRODUCTIONTo be complete, any review of the health hazards of microwave radio exposures

must include a discussion of the research on possible associations between cell phoneusage and brain tumors.

This research is a hot topic politically. Cell phone use has permeated our society,and no one wants to think that use of a cell phone is going to increase their personal risk(or their child’s personal risk) of acquiring a terrifying disease.

The rollout of the cellular communications infrastructure has also created anextremely profitable industry. The telecommunications industry made $3.1 trillion ingross profits in 2010. (Plunkett Research, 2012) This industry has a powerful incentiveto downplay the health effects of EMF, and has funded a good deal of research thatserves to further that aim. Some studies regarding cell phones and brain tumors havebeen funded in large part by the telecommunications industry. These industry-designed studies have generally concluded that the use of cell phones does not create ahealth hazard. And these negative reports have received wide coverage in the newsmedia. However, the study designs funded by industry are more likely to useunblinded protocols and to underestimate risk, as compared to studies funded bypublic bodies. (Levis et al., 2012)

When powerful financial interests are at play, industry funding of favorableresearch studies is often used to influence the political and scientific playing field.We’ve seen this play out in pharmaceutical research, where several recent scandals havehighlighted the distorting effects of corporate financing on research outcomes. In thepast few decades the production of research providing favorable (to corporate interests)results has become something of a science in itself, with corporations essentially gamingthe academic system, funding studies designed to produce favorable outcomes for theirproducts, and hiding studies that do not support their interests. The peer reviewprocess of the scientific journals has not proved to be an adequate defence against thisproblem. (Smith, 2005)

In the research on cell phones and brain tumors, the situation is furtherconfounded by the fact that cell phone usage has only become wide spread in the last 15years or so. The first digital cell phone infrastructure was pioneered in Scandinavia,and the first research that raised concerns about cell phone cancer risks was producedin Sweden in the late 1990’s. But environmental influences that promote cancer gene-rally take years to do so.

Take the question of the potential risk of cell phone use by teenagers. Does thiscell phone use increase the risk of brain tumors later in life? The mass market for cellphone use by teenagers really started after 1995, and extended use of cell phones to surfthe web ballooned after the introduction of the iPhone in 2007. Looking for brain cancertoday in 30 year olds who started using a cell phone in 1997 would be similar to lookingfor lung cancer today in 30 year olds who started smoking in 1997 (and who would bemost likely to develop lung cancer in their 50’s or 60’s).

This means we cannot find great reassurance in “negative” cell phone cancer riskstudies performed 8 or 10 years ago. And similarly, any “positive” findings of cellphone cancer risk to date should produce real concern, since it is possible that they areidentifying only the early cases of a larger problem.

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Three major and ongoing research studies have been performed in the last 10years. One is the INTERPHONE Study, which is funded in major part by the telecom-munications industry. A second study which received much recent media attention isthe “Danish Cohort” study. A third body of research has been produced by the Hardellgroup in Sweden, a research group with no financial support from the telecommunica-tions industry.

THE INTERPHONE STUDYThe INTERPHONE Study is a large standard protocol study of brain and sali-

vary gland tumor risk in relation to mobile telephone use, with branches of the studybeing performed in 13 countries, and combined together to increase the statisticalpower of the results. This study was funded in major part by the wireless communica-tions industry.

The first major summary of this research was published in 2010. This “case-control” study looked at patients with brain tumors (2708 glioma cases, 2409 menin-gioma cases) and matched controls, and compared their estimated cell phone usage todetermine if regular cell phone usage increased the odds of being a brain tumor patient.The authors concluded that “Overall, no increase in risk of either glioma or menin-gioma was observed in association with use of mobile phones.” (Group, 2010)

This reported result was then widely quoted by the press and government agen-cies like the World Health Organization (IARC, 2010) as demonstrating the lack of riskof wireless technology.

However, this study defined a member of the risk group as any subject who “hadan average of at least one call per week for a period of 6 months”. This definition of “regularcell phone use” diluted the risk pool out with lower risk individuals to the point that nodifference between risk and control groups was visible in the study.

Interestingly, the study did report its statistics stratified by total time of reporteduse, and the top decile (greater than 1640 hours use over a ten year interval, averagingout as greater than 3 hours a week) had an increased risk of certain tumors. Individualswho accrued that greater than 1650 hours of use over a 1 to 4 year interval (rangingfrom 8 to over 30 hours a week) had a markedly higher odds ratio of meningioma (OR4.80) or glioma (OR 3.27).

In the discussion of their data showing increased risk within the higher usagegroup, the authors failed to consider the possibility that this data showed a real risk.Instead, they discounted this trend of increased risk in the heavier users, stating thatvarious “biases and errors limit the strength of the conclusions we can draw from theseanalyses and prevent a causal interpretation.” And it is this “biases and error’s”comment that has been quoted by industry apologists in subsequent publications,rather than the study’s actual statistical findings of increased odds of brain tumor withcell phone talk time greater than 3 hours a week over a ten year period, or greater than8 hours a week over a 1 to 4 year period.

The discrepancy between actual data and concluding discussion in this studywas not highlighted by mass media coverage of this study. One must assume thatreporters read the abstract rather than the complete article, and accepted the author’sconclusions without question. Other researchers in the field were more critical in theirassessments of the INTERPHONE project as compared to other published literature onthe subject (Morgan, 2009), and pointed out that the INTERPHONE data really did

SECTION 5 – CELL PHONE USE AND BRAIN TUMOR RISK

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document an increased risk, consistent with studies published by researchers in thefield that were more independent from industry funding sources. (Hardell et al., 2011a)(Levis et al., 2011)

A more recent study from the INTERPHONE group found an increased risk foracoustic neuroma in individuals with > 1640 hours of talk time over up to 5 years ofexposure (OR = 2.79, 95% CI = 1.51 – 5.16). For those subjects who routinely used theircell phone on the same side of the head where they had the acoustic neuroma, the oddsratio was 3.74 (95% CI 1.58 – 8.83). (Cardis and Schüz, 2011)

The most recent study from the INTERPHONE group showed increased oddsratio of glioma and meningioma with greater than 10 years of mobile phone use. Theauthor’s conclusions acknowledged this finding, but stated that “the uncertainty ofthese results requires that they be replicated before a causal interpretation can bemade”. This is an interesting comment, considering that this study result itself wasessentially a replication of the actual findings of the earlier INTERPHONE study.(Cardis et al., 2011)

THE DANISH STUDYA study from Denmark on the risk of mobile phones and brain tumors was

published in the British Medical Journal in 2011. The conclusions of this study werethat “there were no increased risks of tumors of the central nervous system, providinglittle evidence for a causal association”. (Frei et al., 2011)

This study was widely quoted in the media and by government organizations asrefuting the link between cell phones and brain tumors, with headlines like BBC News:“Mobile phone brain cancer link rejected.” (Triggle, 2011)

In this case-control study, the risk group was composed of native Danes who hadacquired a cell phone contract prior to 1995. However, any prior to 1995 corporateusers were excluded from the risk group (this was 32% of the original cohort). Alsoexcluded were all prior to 1995 subscribers who were less than 18 years old at the timethey obtained their first subscription. The study did not determine how often membersof the risk group used their phones, or make any determination as to exposure toportable phones in the home for risk or control group members.

The control group was composed of all Danes aged 30 or older and born after1925 in Denmark. This of course means that the control group included all the earlycorporate subscribers (whom we might call the “power users”), and also included the85% of Danes who obtained a cell phone after 1995.

This contamination of the control group with large numbers of cell phone usersmade the conclusions of the study essentially meaningless. To the BMJ’s credit, lettersthat pointed this out were printed in the same issue with the original article (but appa-rently not read by the members of the press). (Khurana, 2011) (Philips and Lamburn,2011)

The net result of all this was that the public was falsely reassured by mediareports of a peer reviewed article in a prestigious medical journal, when the negativeconclusions of that article were essentially meaningless. (Soderqvist et al., 2012)

THE HARDELL GROUP STUDIESThe first digital cell phone network (2G) was launched in Finland in 1991, and

the cell phone communication infrastructure expanded widely in Scandinavia duringthat decade. In the late 1990’s case reports of brain tumors in cell phone users lead to


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the first of multiple studies produced by the Hardell research group in Sweden. In thiscase control study of data collected between 1994 and 1996 from 233 living patients withbiopsy-verified brain tumors, no clear distinction could be established between cellphone users and nonusers in the patient population, but a trend was observed of in-creased odds of tumor presence in the temporal or occipital lobe on the same side of thehead habitually used to listen to the cell phone. (Hardell et al., 1999)

In 2002 Hardell et al. published another and larger case control study of 649brain tumor cases diagnosed between January 1997 and June 2000. This study (andsubsequent studies by the Hardell group) looked at exposure from both cellular phonesand mobile (cordless) phones connected to land lines. Cumulative hours of cell phoneuse was calculated from questionnaires about phone usage habits. Increased risk ofbrain tumor was found for ipsilateral use (phone habitually on same side of head asbrain tumor site) with both analogue and digital cellular phones and for cordlessphones. Increased risk was also seen for increased duration of exposure. (Hardell et al.,2002)

Another expanded case control study with 1617 brain tumor patients diagnosedbetween 1997 and 2000 was published later that year showed similar findings, with thehighest calculated risk being for ipsilateral acoustic neuroma in analog cellular phoneusers (the older technology). (Hardell et al., 2002)

Hardell et al. analyzed this same data set of 1617 patients for incidence of vesti-bular schwannoma (VS), and found an increased odds ratio for VS associated with theuse of analogue cell phones. They found that the incidence of VS in Sweden had signifi-cantly increased during the time period from 1960 to 1998, with more of this increaseoccurring during from 1980 to 1998. All other brain tumors taken together had alsoshowed a significant yearly increase between 1960 and 1998. (Hardell et al., 2003)(Hardell et al., 2003)

In 2006 and 2007, Hardell et al. published several more studies of brain tumorpatients diagnosed between 1997 and 2003. Cell phones had been in wide use for alonger interval of time, and their data allowed evaluation of latency periods of > 10years duration, and risk for subjects with first cell phone use at < 20 years of age.Cumulative lifetime use of > 2,000 hours showed elevated odds ratios for analog,digital, and cordless phones, and increased risk for malignant tumors with ipsilateralexposure. Risk of malignant tumors was more pronounced in individuals with first cellphone use at less than 20 years of age. (Hardell et al., 2006) (Hardell et al., 2006a)(Hardell et al., 2006b) (Mild et al., 2007)

Later in 2006, Hardell et al. published a pooled review of their data from all six oftheir previous case control studies. (Hardell et al., 2006) And they have subsequentlypublished three more papers updating and consolidating their earlier findings. (Hardelland Carlberg, 2009) (Hardell et al., 2010) (Hardell et al., 2011b)

CRITIQUES AND REVIEWSIn 2004 Kundi et al. published a review of 9 existing epidemiologic studies on the

relationship between cell phone use and brain tumor risk, and found that all studiesapproaching reasonable latencies of exposure time showed an increased relative risk(range 1.3 to 4.6) of brain tumor in cell phone users, with highest overall risk foracoustic neuroma (RR 3.5) and uveal melanoma (RR 4.2) (Kundi et al., 2004)

In 2007 Hardell et al. published a meta-analysis of two cohort studies and 15 case


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control studies on the association between long-term use of cell phones and braintumor. They found increased risk for acoustic neuroma and glioma with ≥ 10 years ofexposure, with higher risk of tumor on the exposed side of the head. (Hardell et al.,2007a)

Hardell, Mild, and Kundi published exhaustive reviews of the existing literatureon this subject in 2007 in the Bioinitiative Report. (Hardell et al., 2007b) (Kundi, 2007)

In 2008, Hardell et al. published two meta-analyses of the existing case controlstudies in the literature including ten studies on glioma and nine studies on acousticneuroma. They found “a consistent pattern of association between mobile phone useand ipsilateral glioma and acoustic neuroma using ≥ 10 years latency period”. (Hardellet al., 2008)

In another meta-analysis published in 2009, Hardell et al. again found “a consis-tent pattern of an increased risk for glioma and acoustic neuroma after > 10 year mobilephone use . . . with highest risk found in the age group < 20 years at time of first use ofwireless phones.” (Hardell et al., 2009)

In a 2009 review, Ahlbom et al. stated that existing studies “do not demonstratean increased risk within approximately 10 years of use for any tumor of the brain”. In away, this statement is a somewhat backhanded acknowledgement of the fact that thepublished research to that date clearly does show increased risk with greater than 10years of use. (Ahlbom et al., 2009)

In 2009 Khurana et al. published a metanalysis of the eleven existing long-termepidemiologic studies on cell phone use and brain tumor risk that met these criteria:Publication in a peer reviewed journal; inclusion of subjects with greater than 10 yearsof cell phone use; analyzing “laterality” of cell phone usage in relation to brain tumorincidence. Their conclusion was that “using a cell phone for ≥ 10 years approximatelydoubles the risk of being diagnosed with a brain tumor on the same (“ipsilateral”) sideof the head as that preferred for cell phone use”. (Khurana et al., 2009)

In 2011 the WHO/International Agency for Research on Cancer (IARC) classifiedradiofrequency electromagnetic fields as “possibly carcinogenic to humans (Group 2B),based on an increased risk for glioma, a malignant type of brain cancer, associated withwireless phone use”. (WHO, 2011) (Baan et al., 2011)

In 2012, Levis et al. published an analysis of published case control studies,pooled analyses, and meta-analyses on head tumor risk with mobile phone use. Theyfound that “in studies funded by public bodies, blind protocols give positive resultsrevealing cause-effect relationships between long-term latency or use of mobile phones(cellulars and cordless) and statistically significant increases of ipsilateral risk of braingliomas and acoustic neuromas, with biological plausibility. In studies funded or co-funded by the cellphone companies non-blind protocols give overall negative resultswith systematic underestimation of risk; however, also in these studies a statisticallysignificant increase in risk of ipsilateral brain gliomas, acoustic neuromas, and parotidgland tumours is quite common when only subjects with at least 10 years of latency orexposure to mobile phones (only cellulars) are considered.” (Levis et al., 2012)

CONCLUSIONSThe current epidemiological research shows that greater than 10 years of cell

phone use incurs a significantly increased risk of ipsilateral brain tumor (glioma ormeningioma). This risk is greater in individuals that start using cell phones as children.


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This means that the RF exposure guidelines for cell phone use cannot be consi-dered to be adequately protecting the public.

In light of these findings, current public policy that essentially ignores biologicalor “nonthermal” levels of RF exposure need to be reconsidered and revised, in order tosignificantly reduce the risk to the public health that is produced by these technologies.


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BIBLIOGRAPHY

Ahlbom A, Feychting M, Green A, Kheifets L, Savitz DA, Swerdlow AJ. Epidemiologicevidence on mobile phones and tumor risk: a review. Epidemiology (2009);20(5):639-652.

Baan R, Grosse Y, Lauby-Secretan B et al. Carcinogenicity of radiofrequency electro-magnetic fields. Lancet Oncol (2011); 12(7):624-626.

Cardis E, Armstrong BK, Bowman JD et al. Risk of brain tumours in relation to esti-mated RF dose from mobile phones: results from five Interphone countries. OccupEnviron Med (2011); 68(9):631-640.

Cardis E, Schüz J. Acoustic neuroma risk in relation to mobile telephone use: results ofthe INTERPHONE international case-control study. Cancer Epidemiol (2011);35(5):453-464.

Frei P, Poulsen AH, Johansen C, Olsen JH, Steding-Jessen M, Schuz J. Use of mobilephones and risk of brain tumours: update of Danish cohort study. BMJ (2011);343(d6387.

Hardell L, Nasman A, Pahlson A, Hallquist A, Hansson Mild K. Use of cellular telep-hones and the risk for brain tumours: A case-control study. Int J Oncol (1999);15(1):113-116.

Hardell L, Hallquist A, Mild KH, Carlberg M, Pahlson A, Lilja A. Cellular and cordlesstelephones and the risk for brain tumours. Eur J Cancer Prev (2002); 11(4):377-386.

Hardell L, Mild KH, Carlberg M. Case-control study on the use of cellular and cordlessphones and the risk for malignant brain tumours. Int J Radiat Biol (2002);78(10):931-936.

Hardell L, Mild KH, Carlberg M. Further aspects on cellular and cordless telephonesand brain tumours. Int J Oncol (2003); 22(2):399-407.

Hardell L, Hansson Mild K, Sandstrom M, Carlberg M, Hallquist A, Pahlson A. Vesti-bular schwannoma, tinnitus and cellular telephones. Neuroepidemiology (2003);22(2):124-129.

Hardell L, Carlberg M, Mild KH. Case-control study of the association between the useof cellular and cordless telephones and malignant brain tumors diagnosed during2000-2003. Environ Res (2006); 100(2):232-241.

Hardell L, Mild KH, Carlberg M, Soderqvist F. Tumour risk associated with use ofcellular telephones or cordless desktop telephones. World J Surg Oncol (2006);4(74):1-10.

Hardell L, Carlberg M, Hansson Mild K. Pooled analysis of two case-control studies onthe use of cellular and cordless telephones and the risk of benign brain tumoursdiagnosed during 1997-2003. Int J Oncol (2006a); 28(2):509-518.

Hardell L, Carlberg M, Hansson Mild K. Pooled analysis of two case-control studies onuse of cellular and cordless telephones and the risk for malignant brain tumoursdiagnosed in 1997-2003. Int Arch Occup Environ Health (2006b); 79(8):630-639.

Hardell L, Carlberg M, Soderqvist F, Mild KH, Morgan LL. Long-term use of cellularphones and brain tumours: increased risk associated with use for > or =10 years.Occup Environ Med (2007a); 64(9):626-632.

Hardell L, Mild K, Kundi M. Evidence for Brain Tumors and Acoustic Neuromas. BioI-nitiative Report (2007b); Section 10(2): 317-343. http://www.bioinitiative.org


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Hardell L, Carlberg M, Soderqvist F, Hansson Mild K. Meta-analysis of long-termmobile phone use and the association with brain tumours. Int J Oncol (2008);32(5):1097-1103.

Hardell L, Carlberg M. Mobile phones, cordless phones and the risk for brain tumours.Int J Oncol (2009); 35(1):5-17.

Hardell L, Carlberg M, Hansson Mild K. Epidemiological evidence for an associationbetween use of wireless phones and tumor diseases. Pathophysiology (2009);16(2-3):113-122.

Hardell L, Carlberg M, Hansson Mild K. Mobile phone use and the risk for malignantbrain tumors: a case-control study on deceased cases and controls. Neuroepidemio-logy (2010); 35(2):109-114.

Hardell L, Carlberg M, Hansson Mild K. Re-analysis of risk for glioma in relation tomobile telephone use: comparison with the results of the Interphone internationalcase-control study. Int J Epidemiol (2011a); 40(4):1126-1128.

Hardell L, Carlberg M, Hansson Mild K. Pooled analysis of case-control studies onmalignant brain tumours and the use of mobile and cordless phones includingliving and deceased subjects. Int J Oncol (2011b); 38(5):1465-1474.

IARC. Brain tumour risk in relation to mobile telephone use: results of the INTERP-HONE international case-control study. Int J Epidemiol (2010); 39(3):675-694.

INTERPHONE Study Group. Brain tumour risk in relation to mobile telephone use:results of the INTERPHONE international case-control study. Int J Epidemiol (2010);39(3):675-694.

Khurana VG. Questions about selection, exposure, and tumour incidence. BMJ (2011);343(d7893; author reply d7912.

Khurana VG, Teo C, Kundi M, Hardell L, Carlberg M. Cell phones and brain tumors: areview including the long-term epidemiologic data. Surg Neurol (2009);72(3):205-14; discussion 214-5.

Kundi M. Evidence for Brain Tumors (Epidemiological). Bioinitiative Report (2007);Section 10(2): 344-380. http://www.bioinitiative.org

Kundi M, Mild K, Hardell L, Mattsson MO. Mobile telephones and cancer--a review ofepidemiological evidence. J Toxicol Environ Health B Crit Rev (2004); 7(5):351-384.

Levis AG, Minicucci N, Ricci P, Gennaro V, Garbisa S. [Mobile phones and headtumours: it is time to read and highlight data in a proper way]. Epidemiol Prev(2011); 35(3-4):188-199.

Levis AG, Minicuci N, Ricci P, Gennaro V, Garbisa S. Mobile Phones and HeadTumours: A Critical Analysis of Case-Control Epidemiological Studies. Open Envi-ronmental Sciences (2012); 6(1-12.

Mild KH, Hardell L, Carlberg M. Pooled analysis of two Swedish case-control studieson the use of mobile and cordless telephones and the risk of brain tumoursdiagnosed during 1997-2003. Int J Occup Saf Ergon (2007); 13(1):63-71.

Morgan LL. Estimating the risk of brain tumors from cellphone use: Published case-control studies. Pathophysiology (2009); 16(2-3):137-147.

Philips A, Lamburn G. Updated study contains poor science and should be disregarded.BMJ (2011); 343(d7899; author reply d7912).

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Smith R. Medical Journals Are an Extension of the Marketing Arm of PharmaceuticalCompanies. PLoS Medicine (2005); 2(5):0364-0366.

Soderqvist F, Carlberg M, Hardell L. Review of four publications on the Danish cohortstudy on mobile phone subscribers and risk of brain tumors. Rev Environ Health(2012); 27(1):51-58.

Triggle N. Mobile phone brain cancer link rejected. BBC News, (2011, October 20).http://www.bbc.co.uk/news/health-15387297

WHO. IARC Classifies Radiofrequency Electromagnetic Fields as Possibly Carcinogenicto Humans. World Health Organization, Press Release, 31 May 2011:http://www.iarc.fr/en/media-centre/pr/2011/pdfs/pr208_E.pdf


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CONCLUSIONS AND RECOMMENDATIONSADVERSE BIOLOGICAL EFFECTS—THE SCIENTIFIC EVIDENCE

In the previous sections we have reviewed the increasingly robust body of scien-tific evidence that excessive RF exposure can cause both acute and chronic adversebiological effects:

ACUTE EFFECTSIn susceptible individuals, excessive RF exposure can provoke acute symptoms.

The most common symptoms are sleep disturbance, headache, irritability, fatigue, andconcentration difficulties. Other symptoms may include depression, dizziness, tinnitus,burning and flushed skin, digestive disturbance, tremor, and cardiac irregularities.

As physicians, some of us have seen patients who are experiencing this problem,and are aware of the connection with RF exposure. Research suggests that 3 to 5% ofthe population fit into this category. If this is the case, there may be 4,700 people inEugene who react to RF exposure in some way, and know it.

These symptoms are not uncommon in the population, of course. And in allprobability there are many other people in Eugene who are having problems withinsomnia or fatigue--problems provoked by EMF exposures--but are unaware of theconnection between cause and effect.

Any significant increase in RF exposure in our residential areas will make theseindividuals more symptomatic. Such increases are likely to push additional individualsabove their tolerance threshold, producing new cases of these problems. If increased RFlevels from repeated daily transmissions between smart meters and their control towerspushed an additional 1% of the community into acute reactivity to RF exposures, thiswould mean an additional 1500 people in our city with insomnia, headaches, fatigue,ringing in the ears, or other debilitating symptoms.

CHRONIC EFFECTSChronic exposure to RF can also cause chronic physiologic changes, including

altered endocrine function (both melatonin and other hormones), and increased oxidantstress that can lead to increased levels of cancer and male infertility. The public isalready being subjected to increased levels of RF from wireless communications. In-creasing the total load of transmission further will increase the occurrence of theseadverse consequences.

PERSPECTIVE AS WE MOVE FORWARDAt the beginning of the last century, people began to use vehicles powered by

internal combustion engines that burned gasoline. Gasoline power was cheap andconvenient, and greatly increased the mobility of the population. And the companiesthat sold the gas and the cars made a lot of money.

This use of fossil fuels has had long term consequences--increased atmosphericCO2 which through the greenhouse effect would lead to global climate change. Initi-ally, these consequences went unrecognized. Then the scientific community began topredict and measure them.

Public acknowledgement of these consequences has gone through several stages.First, the science was ignored. Then the science was attacked or denied by those whoseeconomic interests were threatened by it. Public recognition of the problem is onlyarriving as the long term consequences of climate change are beginning to be felt.

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The use of wireless communications technology is following a similar trajectory.Wireless communication is convenient, and increases our mobility. The installation ofwireless networks is also significantly cheaper than installation of hard-wired networks.And the companies that provide these networks and the tools that we use to accessthem are making a great deal of money.

For decades, the biological consequences of this form of communication wentunrecognized by both the public and the scientific community. As scientific evidence ofbiological and health effects began to emerge, this evidence was initially ignored bygovernment regulating bodies, the media, and the public. As this evidence is gettingharder to ignore, it is now being attacked or denied by the telecommunicationsindustry. Wide public recognition of the problem and the science that describes it willarrive as the problem becomes more severe, and more people get sick.

The previous sections of this report describe the increasing body of science thatclearly demonstrates the existence of adverse biological effects from chronic RF expo-sure. It is important for EWEB’s Board and staff to recognize that this science is real,and that the science isn’t going to go away. As the wireless communications infra-structure continues to grow, the magnitude and duration of public exposure are goingto continue to increase, and the number of people with acute or chronic effects from thisexposure will continue to grow. As recognition of the problem by the public increases,exposures and infrastructure that are currently unquestioned will become politicallyunacceptable.

EWEB has moved slowly in the process of investigating AMI technology. Recog-nition of the potential health effects of excessive RF exposure to the public should causethis appraisal to become even more deliberate and circumspect. EWEB needs to avoidinvesting millions of dollars on infrastructure that becomes part of the problem.Instead, EWEB needs to think about making engineering choices that recognize thisproblem, and seek to become a part of its solution.

RECOMMENDATIONSBASIC PRECEPTS FOR RESIDENTIAL EXPOSURES TO RF TRANSMISSIONS• Excessive RF exposure can cause acute problems (headaches, insomnia, fatigue,

vertigo, tinnitus, other symptoms of EHS).• Excessive RF exposure can also cause chronic problems (oxidative stress, cancer,

male infertility).• Constant RF transmission is probably harmful, even at low levels, and should be

avoided.• Frequent and repetitive intermittent transmissions are also probably harmful,

and should be avoided.• Nocturnal exposures are more problematic than daytime exposures, because of

RF’s potential to suppress nocturnal melatonin secretion and disturb sleep, andbecause night is the time when we rest and heal from stresses (including oxida-tive stress).

• Occasional and infrequent daytime exposures are much less likely to cause anincrease in chronic problems for the population at large.

• Occasional and infrequent daytime exposures are still likely to provoke acutesymptoms in a small percentage of the population.

SECTION 6 – CONCLUSIONS AND RECOMMENDATIONS

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Based on our review of the existing science, we suggest that the above basicprecepts be considered when thinking about residential exposures to microwave RFtransmissions. We consider this to be important for the population at large, and evenmore important for those in our community who suffer from symptoms of electrohy-persensitivity. For all of us, our homes are the place where we rest and where we sleep,where we rejuvenate ourselves from the stresses of the wider world. It is important thatour residential environments be a place where this can occur. Our homes need to bepart of the solution, not part of the problem.

EWEB SHOULD ADOPT A POLICY OF MINIMIZING THEIR RF FOOTPRINT IN THE COMMUNITY

A recognition of these precepts should lead EWEB to adopting a policy of mini-mizing their infrastructure’s RF footprint in the community as much as possible duringregular operations. This doesn’t mean that staff would throw away their cell phonesand communicate by semaphore. But it would mean that instead of combatting or igno-ring the possibility that more RF in the community could cause harm, EWEB shouldacknowledge the potential risks of excessive residential exposure.

This would mean that such potential risks would be seriously considered in anydiscussion of the total risks and benefits (the “Total Bottom Line”) in deciding whetherto use RF technology for any given purpose. If, after such a discussion, a considereddecision is made to use RF technology, then these same potential risks should be takeninto serious consideration in determining how to use this technology in a manner thatwould minimize potential harm to the community.

In other words, don’t use RF when you don’t have to. Go hard-wired whereverit is feasible to do so. And if you do use RF, design the technology to use as little of it aspossible.

Current engineering choices in AMI technology have not been designed withthese goals in mind, since the industry has not had an practical incentive to recognizethe problem and to “work the problem”. But EWEB as a purchaser of technology couldchoose to push vendors towards designing and providing hardware options that wouldaddress these goals. This would put EWEB in the position of being part of the solutionrather than just another part of the problem.

FLAWS IN THE CONCEPT OF “OPTING OUT”It has been suggested that people who have problems with EHS or concerns

about health exposures to RF can be taken care of by creating an “opt out” program,allowing them to decline the installation of a smart meter on their home. This sugges-tion overlooks some obvious and important problems:

• You can’t “opt out” of exposure to your neighbor’s meter, that is ten feet awayfrom your bedroom window.

• You can’t “opt out” of all the meters on the wall of your rental apartmentcomplex. Or the ones on the wall of the complex right across the alley from yourapartment.

• You can’t “opt out” of exposure to the meter on the other side of your bedroomwall if you are a baby in a crib.

• You can’t “opt out” of exposure to transmissions from the radio tower 100 metersfrom your house.


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The idea of an “opt out” program is an effort to address the concerns of peoplewho are personally worried about RF exposures, either because they are aware ofhaving acute reactions to these exposures, or because they have a general concern aboutthe acute or chronic effects from such exposure.

But a voluntary “opt out” program does not protect the community at large fromadverse effects that they are unaware of and unconcerned about. For example, thecurrent research shows that cancer rates are higher in residences near cellular transmis-sion towers. Most people don’t know this. How does a voluntary “opt out” programhelp the person who develops breast cancer three years after installation of a transmis-sion tower across the street from her house? She didn’t know it was a problem . . .

DISCUSSION OF THE TECHNOLOGY OPTIONSHow would adopting these precepts and goals play out in practice? Several

factors come into consideration:• The scientific evidence on biological effects of RF, summarized in the basic

precepts listed above.• The various possible functional goals of the AMI program:

– Reducing operating costs by reading and switching meters remotely.– Training customers to conserve electricity.– Shifting time of use by measuring and billing time of day usage.– Absorbing fluctuations in renewable energy supply by “demand/response”

control of usage.• The different AMI technologies that are available.

When our committee puts our best understanding of these three factors intoconsideration, and look at each choice in AMI technology through this combined frameof reference, the discussion runs something like this:

MESH NetworkFrom a biological point of view, AMI meters that are transmitting several times a

minute can be considered to be an essentially constant source of RF exposure. Wherethese networks have been established in the last two years, large increases in reportedacute symptoms have occurred. We think it is medically probable that that this techno-logy will be found to cause an increase in chronic health problems, including increasedcancer, once sufficient time has passed for this to occur.

EWEB staff has already explored and tested a MESH option and chosen not to goforward on that path. We applaud EWEB’s decision to steer away from this technology.

Powerline Communications (PLC)From a public health point of view, PLC is less problematic than an RF AMI

communication technology. And PLC could be used to reduce operating costs, traincustomers to conserve electricity using in-house monitors, and record and transmit timeof day usage measurements to the utility.

EWEB has turned away from the choice of PLC for two main reasons. Firstly,because it won’t allow measurement of water meter readings, limiting the reduction ofoperating costs from elimination of meter reading. Secondly, because PLC as currentlydesigned does not have the bandwidth to sustain rapid “demand/response” controlcommunications.

There are some other technical considerations that make PLC infrastructure moreawkward to set up in an environment where some transmission wires are on poles and


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others are underground.If “demand/response” was not on the table, and if a Total Bottom Line analysis

of the options included the potential health costs of using RF technology, the financialanalysis of the PLC option might look different than it did in the AMI Business Caseprepared by EWEB staff last April. A decision to read the water meters once every 3months rather than monthly could also realize additional savings, if this option wasunder serious consideration.

Fiber Optic CommunicationsFiber optic communication between the utility and the house meter is an ideal

solution from a health/environmental point of view, providing ample bandwidthwithout RF transmission. However, this technology would be quite expensive to install,especially in the parts of Eugene where the power grid is underground. The cost mightbe prohibitive for EWEB at this point in time. Like PLC, fiber optics would not commu-nicate with the water meters.

Tower Communications Network (SENSUS)The engineering system that EWEB is currently considering is the SENSUS

company’s technology, where central towers communicate directly with the meters onthe houses. SENSUS owns the sole rights to a certain transmission frequency on thecommunications bandwidth. This allows them to use more powerful radios on thesmart meters, strong enough to communicate directly with a transmission towerwithout requiring that the message be passed from meter to meter across a MESHnetwork. The community would be divided into about 13 zones, each of which wouldhave a communication tower placed on an existing EWEB property within the zone,and these towers would communicate directly with the house electric meters and withradios on the house water meters.

With 88,000 electric meters and 52,000 water meters in the city, an average zonewould have 6770 electric meters and 4000 water meters in the zone. How long a trans-mission interval would be required for a tower to collect the data from 10,770 meters?We don’t know the answer to this question, and EWEB engineers may not know either,until they set up a trial system and test it out. But clearly, the RF footprint created bythis sort of system could vary significantly, depending on how the system was used.

It is routine for utilities to collect data from these systems four times a day. Butthis routine was developed without consideration of the potential health risks of exces-sive RF transmission in the community. And usage data does not need to be collectedthis frequently to achieve the main goals of the AMI program. From a practical point ofview, the utility will continue to bill once a month, and in theory could remotely collectthat usage data once a month, minimizing the community’s exposure to frequent andrepetitive RF transmissions.

We think usage data should be collected from these meters at an interval of onceevery two to four weeks, with transmission occurring during the daytime hours. Trans-mission events at this level of infrequency would represent a minimal increase in the RFexposure to the community, and would be unlikely to significantly increase the risk ofchronic health problems in the community.

Each data transmission event would still be likely to provoke acute symptoms inindividuals with EHS who lived near these transmission towers. But if these eventsoccurred at an interval of once every two weeks or longer, and at a predictable time of


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day, this might be a manageable level of exposure for those individuals.In our informal discussions with EWEB engineers, we have been told that they

have looked into the issue of data collection frequency, and that the longest that theycould go between data collection events with the SENSUS system would be about threeand one half days.

This would appear to be a case where the technology has not been designed withan eye to minimizing RF transmission. Six daily time-of-use intervals times 30 daysequals 180 intervals of usage data. We think that if an iPod can store 64 gigabytes ofmusic, it ought to be possible to give a smart meter enough memory to store 180readings before transmitting them to the utility. We would recommend that EWEB asktheir potential vendors to provide a meter with enough memory to store two to fourweeks of data, to enable the minimal RF footprint that we are recommending.

Tower communications and the water metersWater usage is billed once a month, and a single monthly reading of the meters

would collect this data with minimal RF exposure to the community. Again, this datacollection should occur in the day time, not in the middle of the night.

Tower communications and “demand/response” From a public health perspective, the use of the system for “demand/response”

load control is more problematic. As we understand it, a lot of this transmission wouldoccur at night, when wind power production is high and demand is low. Towerswould be transmitting every 15 minutes, to turn one cohort of water heaters on andanother cohort off. And the protocols required by the grid would require a two waycommunication with each meter in the cohort, acknowledging that house’s participationin the cohort at that time.

This will involve a good deal of transmission in the system every 15 minutes,both from the towers potentially talking to hundreds of meters across the neighbor-hood, and from the 2 watt radios on each house in the cohort talking back to the tower.

Communication of this frequency from the towers would be a significant additi-onal layer of frequent nocturnal RF signal exposure to the residences within a fewhundred meters of the towers.

And enough cohorts of houses are involved, the transmissions from the meterson the houses could also increase the signal density in the residential areas enough todisrupt melatonin and sleep in a percentage of the population.

We think that this frequent level of activity in the demand/response systemwould be a significant additional RF burden on the community. It would make life inthe residential area significantly more difficult for those individuals in the communitythat is currently already having acute problems. It would probably cause the onset ofacute symptoms in a small percentage of the population who are not currently experi-encing them. And it would be likely to further increase the incidence of chronic adverseRF effects in our community.

Demand/response and the in-home “Zigbee” networkOnce the AMI smart meter on the house gets a demand/response signal from the

control tower, it must tell the water heater in the house to turn on. Existing technologydoes this through wireless communication over a “Zigbee” WiFi network in the home.This network is maintained by constant transmissions of signals between the meter andthe Zigbee appliances in the home network, 24 hours a day.


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The research that we’ve reviewed above shows that biological effects can beproduced by low power levels of RF exposure, and that prolonged, constant exposurescan have effects even at extremely low exposure levels.

For demand/response to work in the community, at least 20% of the homes inthe community will need to volunteer for the program, and have it set up in theirhouses. In undertaking to install demand/response infrastructure in its current form,EWEB would be making several presumptions:

• A presumption that the Zigbee system is low enough in power that it won’tcause any harm.

• A presumption that public acceptance should be good, since the public at largeisn’t really concerned about the health effects of RF at this time.

• A presumption that since most people have WiFi now anyway, they aren’t goingto be concerned about the additional exposure.

• A presumption that because the system will be voluntary, so no one can or willcomplain about involuntary exposure.While it may be true that the public isn’t that worried at present, and that many

people have WiFi in their homes and aren’t worried about it at all, we do not think thatEWEB can assume that this will continue to be the case throughout the investment life-time of the installed demand/response infrastructure.

As we’ve discussed in the prior sections, signals of WiFi power are strongenough to cause severe symptoms in individuals with EHS. Several hours of WiFiexposure has been shown to cause damage to healthy sperm. The general public isunaware of these facts. But we think that this is less likely to be the case 8 or 10 yearsfrom now, much less 20 years from now. As increased exposure to wireless RF commu-nications causes more health problems in the population, and the scientific evidence ofthis effect continues to become more robust, public attitudes about this exposure aregoing to change. Within 20 years, the public—especially parents with young children—will be much less open to having constant WiFi signal in their homes. If this assump-tion is correct, the purchase of many millions of dollars in demand/response infra-structure that is based on wireless in-home communications would appear to be anunwise investment.

The “demand/response” infrastructure is still immatureWe think that the “demand/response? infrastructure is still immature. This tech-

nology may be mature from an engineering point of view, in that “it works”. But froma public health perspective, it is completely immature. We state this because the tech-nology has been designed around RF communications (because this infrastructure isquicker and cheaper to set up than a hard wired system) without any consideration ofthe health effects of exposure to excessive or prolonged RF transmissions, and withoutany considered effort to engineer the hardware or the software protocols in a way thatwould minimize such exposures.

The Zigbee network is a case in point. In modern construction, most electricmeters are sitting on the outside of the circuit breaker box. Within that breaker box,there are dedicated circuits with hard-wired connections to the electric water heater, theelectric stove, and the electric clothes drier.

Why not set up communications between these utilities with powerline commu-nications protocols over these hard-wired connections? All it would take would be


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some intelligent technology in the 220 circuit breakers for the appliances, and a smartswitch at the other end of the circuit, and connections to the network controls in thesmart meter that is plugged into the breaker box. All this could be done withoutputting any RF transmission into the house?

Why hasn’t this been done yet? Because a wireless solution is easier to install?Because changing the hard wiring would require changing electrical codes? Because noone thinks it’s necessary to get this clever, since no one is worried about RF exposures?

Solutions like this could be created, if industry and government had enoughincentive to work the problem, rather than to deny the existence of the problem. Untilsuch alternatives to constant in-home RF exposure are developed, we think that EWEBwould be wise to avoid getting married to this technology. Developing demand/response using a constantly transmitting in-home RF network will mean investing agreat deal of money in infrastructure that is likely to become extremely unpopularwithin the next 10 to 15 years. What we look at now as “quick and cheap” will come tobe viewed as “quick and dirty”.

Other communication optionsWe’ve been told that the powerline communication option is not a feasible solu-

tion for demand/response control, since it lacks the bandwidth necessary for rapidcommunications between server and meters.

We think that serious consideration should be given to the potential use ofbroadband internet connections for demand/response communications. We unders-tand that EWEB does not have the financial power to build their own fiberoptic networkat this time. But in 2010, 82% of the households in our part of the state had broadbandinternet connections, and this proportion continues to grow. Would it be technicallypossible to use these wired internet connections to communicate with the vast majorityof the electric meters in our city, rather than building a new wireless infrastructure todo the job? Broadband internet communications would certainly have the bandwidthto do this, and a demand/response system is not expected to require the participationof every household in the community. If we acknowledge the health risks of RFcommunication (especially the robust night-time communication expected for demand/response control), then an internet-based demand/response control system should begiven serious consideration.

IN CONCLUSIONWe hope that our report and recommendations will be helpful to EWEB staff, the

EWEB Board of Governors, and to members of our community. We think that review ofthis information should allow a more realistic appraisal of the health risks involved inestablishing an AMI network that utilizes microwave RF communication. Such ameasured and realistic appraisal is a necessary part of the Total Bottom Line Analysisthat EWEB has promised to bring to any major initiative in our community.

This is a lengthy document, and discusses complex issues. We would welcomethe opportunity to meet with EWEB staff and members of the Board, in order to give amore extensive audiovisual presentation and clarification of this material, and toanswer any questions that you wish to ask us about this research.

We hope to be part of an ongoing dialogue about the potential health effects ofRF technology, as EWEB continues to deliberate on the various choices that they facewith the AMI program.


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Diplomats’ Mystery Illness and Pulsed Radiofrequency/Microwave Radiation

Prof. Beatrice Alexandra Golomb, MD PhD (2018)

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Diplomats’ Mystery Illness and

Pulsed Radiofrequency/ Microwave Radiation

Beatrice Alexandra Golomb, MD, PhD

Corresponding Author:

Beatrice Alexandra Golomb, MD, PhD

Professor of Medicine

UC San Diego School of Medicine

858 558-4950 x201

[email protected]

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Abstract:

Importance: A “mystery” illness striking US and Canadian diplomats to Cuba (and now China) “has

confounded the FBI, the State Department and US intelligence agencies.” Sonic explanations for the so-called

“health attacks” have long dominated media reports, propelled by peculiar sounds heard and auditory

symptoms experienced. Sonic mediation was justly rejected by experts. We assessed whether pulsed

radiofrequency/microwave radiation (RF/MW) exposure can accommodate facts - including unusual ones -

reported in diplomats.

Observations: 1. Noises: Chirping, ringing or grinding noises were heard at night, during episodes reportedly

triggering health problems, by many diplomats. Some reported that sounds were localized with laserlike

precision; or said the sounds seemed to follow them (within the territory in which they were perceived). Pulsed

RF/MW engenders just these apparent “sounds” via the “Frey effect.” Perceived “sounds” differ by head

dimensions and pulse characteristics, and can be perceived as located behind, in or above the head. Ability to

hear the “sounds” depends on high frequency hearing and low ambient noise. 2. Signs/symptoms: Hearing loss

and tinnitus are prominent in affected diplomats – and in RF/MW-affected individuals. Each of protean

symptoms that diplomats report, also affect persons reporting symptoms from RF/MW: Sleep problems,

headaches, and cognitive problems dominate in both groups. Sensations of pressure or vibration figure in each.

Both encompass vision, balance and speech problems, and nosebleeds. Brain injury and brain swelling are

reported in both. 3. Mechanisms: Oxidative stress provides a documented mechanism of RF/MW injury

compatible with reported signs and symptoms; sequelae of endothelial dysfunction (yielding blood flow

compromise), membrane damage, blood brain barrier disruption, mitochondrial injury, apoptosis, and

autoimmune triggering afford downstream mechanisms, of varying persistence, that merit investigation. 4. Of

note, microwaving of the US embassy in Moscow is historically documented.

Conclusions and Relevance: Reported facts appear consistent with pulsed RF/MW as the source of injury in

Cuba diplomats. Non-diplomats citing symptoms from RF/MW, often with an inciting pulsed-RF/MW

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exposure, report compatible health conditions. Under the RF/MW hypothesis, lessons learned for diplomats

and for RF/MW-affected “civilians” may each aid the other.

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Introduction:

More than two dozen American diplomats in Cuba1,2

, and their families3, plus a smattering of Canadian

diplomats in Cuba4,5

and their families6, reportedly developed a “mystery” illness

4,7-9 that “has confounded the

FBI, the state department and US intelligence agencies”9, “baffling US officials”

10: “‘It’s just mystery after

mystery after mystery’”10

. Problems began in 2016, began to be widely reported in 2017, and as of January

2018, “‘We are not much further ahead than we were in finding out why this occurred,’ Undersecretary of

State Steve Goldstein said”1. Similar problems first were recognized in China in April 2018, and “a number of

diplomats at the US consulate in Guangzhou, China had been sent home with similar symptoms”2,11-13

– by

June’s end, “at least eight” from the consulate in Guangzhou, and “at least 11” from China more broadly14

.

Media reports have long characterized these so-called “health attacks”15-17

as “sonic attacks”2,7-10,18-20

.

This characterization persisted despite rejection of sonic explanations by experts8-10,21,22

. E.g. “No single, sonic

gadget seems to explain such an odd, inconsistent array of physical responses”10

. Per psychoacoustics expert

Joseph Pompei: “‘Brain damage and concussions, it’s not possible.’…‘Somebody would have to submerge

their head in powerful ultrasound transducers’”10

. Some suggested a viral hypothesis1, but this fails to explain

many features of these cases, including the strange noises associated with inciting events in some; and there

isn’t a known viral illness with a compatible profile of symptoms. Though “officials told senators the US

government knew of no weapon, sonic or otherwise, that could produce the effects seen in the Cuba patients”1,

to this date, some media sources continue to reference sonic attacks2.

A different explanation is proposed that, it is suggested, better accommodates the facts – including the “odd,

inconsistent array of physical responses”10

and other “mysterious” and protean features reported. Reported

features are assessed for compatibility to known effects of radiofrequency/ microwave radiation (RF/MW),

particularly pulsed RF/MW. Symptoms and signs are assessed against symptoms and signs reported by people

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that report health effects from RF/MW exposure – a condition that has been termed “radiofrequency

sickness”23

, “microwave syndrome”24

, or to encompass people experiencing problems from exposures beyond

a specific part of the electromagnetic spectrum, “electromagnetic hypersensitivity”25-29

, “electrosensitivity”30-32

or “electrohypersensitivity”33-38

.

Methods:

Features of diplomats’ “health attacks” – origins, symptoms, and findings are delineated, and examined in

relation to evidence regarding symptoms from RF/MW.

Features to be examined for compatibility with an RF/MW-explanation include the following. Strange noises

were heard by some diplomats during apparent inciting episodes5,11

. The noises that were heard differed

markedly for different diplomats5. The various descriptions included high pitched chirping similar to crickets

or cicadas, ringing and grinding10

. The noises were heard primarily at night10

. Other diplomats heard no

noises5, and were not aware of any inciting episodes – just onset of symptoms. In at least some cases, incidents

(and noises) were confined to “parts of rooms with laser-like specificity”10

. And, within the area in which a

sound was perceived, it seemed to follow the person around the room11

.

Auditory symptoms are a prominently reported and distinctive feature (though not present in all) and include

hearing loss6,9,10,15,17,39

and tinnitus5,6,9,40

, and particularly during inciting episodes in some, ear pain40

.

Other symptoms are protean and vary markedly from individual to individual -- “an odd, inconsistent array of

physical symptoms”10

. Sleep symptoms6,41,42

, headache5,6,15

, cognitive dysfunction6,10,40,41

, and fatigue6,40

are

prominent among the “nonspecific” symptoms. In some, problems were temporary and apparently recovered

with time away from the exposure9; others experienced persistent problems

3,5.

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Potentially objectively measurable problems with speech9,10

, balance9,10,41,42

and vision41,42

as well as epistaxis

(nosebleed)9 are a feature in some. Peculiar sensory symptoms of pressure and vibration are reported

41. Brain

injury3,5,9,43

, white matter abnormalities44

, and brain swelling5, 9

have been reported.

To assess compatibility of symptoms in diplomats with those experiencing symptoms from RF/MW, we focus

on those who are symptomatic in each group. “Only a minority of embassy staff were stricken”11

and it is these

who have been reported upon and studied. The appropriate comparator are the minority who are symptomatic

from RF/MW exposures.

Peer reviewed publications are the primary source of information. However, the most authoritative source for

information about symptoms and experiences of individuals is affected individuals themselves: peer review

confers no benefit and has no power to adjudicate individuals’ reports. For this reason, peer reviewed literature

to address issues of science is complemented by sources that have elicited and reported on symptoms and

experiences of diplomats, or of RF/MW affected individuals, extending to encompass news reports, surveys,

statements of affected individuals, or when applicable other “gray literature”. For diplomats, news/ media

reports are complemented by a Jama report focused on neurological symptoms in diplomats41

. Information that

references “news,” rather than science, also cites media sources.

Mechanisms by which RF/MW may cause reported problems are cursorily addressed. Sources of RF/MW

reported to affect the comparator group, and potential RF/MW sources of diplomats’ symptoms, are briefly

reviewed.

Results:

Table 1 reviews characteristics of noises reported by diplomats in inciting episodes, and compatibility with

RF/MW. Pulsed RF/MW in the 2.4-10,000MHz range produces perceived noises that resemble sounds “such

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as a click, buzz, hiss, knock, or chirp” – just as diplomats report45

. Ability to hear Frey “sounds” is reported to

depend on high frequency hearing, and on low ambient noise45

– through a phenomenon termed the “Frey

effect.” (Synonyms include “microwave auditory effect,” “RF hearing” and variations of these.) This fits

reports that noises were not universally perceived. The requirement for low ambient noise accounts for

perception of “sounds” primarily at night10

. The primary pitch perceived reportedly relates to head

dimensions45

– in addition to pulse waveform and other characteristics -- accounting for different “sounds”

perceived by different diplomats. Sounds were localized with “laserlike” specificity in some cases, supposedly

defying known physics10

. This may defy the physics of sound, but not the physics of RF/MW: lasers are

electromagnetic radiation (EMR). One diplomat reported that the sound seemed to follow him within the space

in which it was heard11

. Frey “sounds” are also reported to follow the person, often perceived as slightly

behind the head, regardless of the body orientation relative to the source of radiation45-47

. Of note, Frey

induction is not governed by average radiation intensity, but the energy in a single pulse45

. (Analogously, if a

jackhammer hit each 2 minutes, the low time-averaged pressure would not explain the damage.)

Table 2 reviews diplomats’ symptoms and signs, and compatibility of these with RF/MW.

Auditory symptoms, including tinnitus, hearing loss, and ear pain or pressure are prominent in diplomats41

and

in persons affected by RF/MW48-51

. Symptoms are protean in both groups. Prevalent among non-auditory

“nonspecific” symptoms are sleep problems, headaches, cognitive problems, and to a lesser degree dizziness

and nausea9,10,40,41,48-51

. Additional more specific symptoms that are in principle objectively measurable include

problems with balance, speech, vision, and epistaxis, i.e. nosebleed9,10,41,48,49,51

. Peculiar sensory symptoms are

reported in both, including pressure and vibrations41,49

. Reported brain findings have included brain swelling,

problems consistent with traumatic brain injury, and white matter abnormalities. Each such feature is also

observed in those with symptoms ascribed to RF/MW.

Table 3 lists symptoms commonly reported in diplomats, together with percentages reporting each symptom,

for symptoms assessed in the neurological appraisal of Cuba diplomats or mentioned in news reports9,10,40,41

.

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These symptoms (when elicited) are ranked by prevalence, in surveys of persons exposed to specific sources of

RF/MW, or with symptoms ascribed to EMR exposure48-51

. Fractions of symptomatic diplomats who report

each symptom41

appear similar to fractions of those symptomatic with EMR symptoms, who do so. Comparing

rates in diplomats41

to those in a peer reviewed study of EMR affected individuals50

on symptoms tallied in

both, symptom rates were: Headache 81%-vs-81%; Cognitive problems 81%-vs-81%; Sleep problems 86%-vs-

76%; Irritability 67%-vs-56%; Nervousness/Anxiety 52%-vs-56%; Dizziness 67%-vs-64%; Tinnitus 57%-vs-

63%41,50

. Thus, rates conform closely.

The rates of symptoms reported for diplomats appear within reported variation, for studies of persons affected

by RF/MW/EMR. Sleep problems were reported somewhat less frequently in EMR affected persons in the

Kato study (76%), than in diplomats – but reported sleep problems, or their byproduct fatigue (for which

prevalence was not recorded in the diplomat study), dominate the number one symptom position in studies of

RF/MW affected persons (Table 3), and prevalence of sleep problems was higher than for diplomats in some

other studies of RF/MW affected persons52

. Of note, the Kato study was performed in Japan, where the

traditional diet is rich in fish, which supply the long-chain omega-3 fatty acids that reportedly benefit sleep and

reduce irritability53,54

(the two symptoms that were >3% lower than in affected diplomats).

The protean character of symptoms in diplomats19

(as for RF/MW-affected individuals) has led some to infer

that a single cause cannot account for all. But a number of reports, in a number of nations and settings, tie

RF/MW exposure (in vulnerable individuals) to each of the problems reported in diplomats. The coherence of

findings in those citing affects of RF/MW, with findings in diplomats, supports a common cause within each

group – and across the two groups. Of note, a protean suite of generally the same symptoms – but in a different

distribution – is reported in other conditions that are tied to mitochondrial alteration and oxidative stress55-57

(mechanisms which each promote the other58,59

). RF/MW is tied to these mechanisms60-66

. However the

distinctive prominence of sleep and auditory symptoms, the peculiar somatic sensory experiences of pressure

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and vibration, and the noises perceived during apparent inciting episodes, are relatively distinctive features –

distinctive to diplomats’ reports, and to reported RF/MW problems.

Table 4 reviews several mechanism considerations. Central to this is the critical role of oxidative stress, and

the relevance of oxidative stress to potential auxiliary mechanisms, such as mitochondrial dysfunction, blood

brain barrier disruption, membrane alterations, impaired blood flow, apoptosis, effects on voltage-gated

calcium and anion channels, and triggering of autoimmune reactions. (In some cases effects are reciprocal –

oxidative stress promotes mitochondrial dysfunction, calcium channel effects, inflammation, autoimmunity –

which in turn can promote oxidative stress.) One analysis found that of 100 evaluated studies that examined the

relationship of low level RF/MW to oxidative stress in biological systems, 93% supported a connection60

. A

role for oxidative stress in RF/MW/EMR affected persons is cemented by evidence that gene polymorphisms

adverse to antioxidant defense are significantly more prevalent in persons experiencing symptoms from

RF/MW/EMR67

. Additionally, levels of a particular antioxidant – melatonin – known to be critical for RF/MW

and broader EMR defense are consistently low in affected persons (assessed by a urinary metabolite)33

.

Oxidative stress has been tied to each of the symptoms and conditions reported in diplomats, and RF/MW

affected persons.

Also noteworthy is the repudiation of psychogenic causation in the evaluation of diplomats11,41

, which holds

for RF/MW affected persons as well. Case narratives for those affected by RF/MW underscores that for many,

symptoms developed and progressed when affected parties as yet had no knowledge that an RF/MW emitting

device had been introduced, nor that one could cause problems49,52

. A Swiss Telecom funded study found that

sleep problems related to the electromagnetic field strength of the transmitter, and did not correlate with

personality traits tied to worry about health48,68

. The circumstance that some report being affected severely by

levels of exposure that cause others no problem, is reviewed in the context of effect modification, variations in

antioxidant defenses, and demonstrated variable involvement of secondary mechanisms such as autoimmune

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10

activation33

. In fact, analogous marked differences in harm or development of health effects are well known for

other exposures, such as peanuts, penicillin, and pesticides. For EMR affected persons67

– as for many other

exposure-related illnesses – genetic influences on phase I or phase 2 detoxification, as well as factors that

inhibit or compete for detoxification systems, play a documented role in who develops health effects69-74

.

(Phase 2 detoxification encompasses protections against oxidative damage.)

Table 5 briefly addresses the range of RF/MW sources that have been presumptively tied to problems. It

observes that RF/MW/microwave radiation is known to have been used on the US embassy in Moscow – there

is precedent for use on diplomats75,76

. That instance, though with presumably differing details of exposure, led

to (disputed) reports of health effects in embassy staff, and shielding efforts by the US. Since the exposing

device can be outside the building – and typically has been, for persons affected by RF/MW-emitting utility

meters48

– failure of the FBI to find devices in sweeps of diplomats’ rooms remains compatible with this

explanation.

Discussion:

Recap of Findings:

Health effects reported by US and Canadian diplomats (and family members) in Cuba and China, and the

circumstances surrounding inciting episodes, are consistent with effects of RF/MW. Reports of perceived

sounds fit known characteristics reported for the Frey effect (RF hearing, microwave hearing): Sounds were

heard by some but not other diplomats during inciting episodes, sounds differed in character from person to

person, sounds included chirping, ringing and grinding, sounds were heard predominantly at night. Sounds

were localized with “laserlike” specificity in some of the cases, and within that localization, seemed to follow

people. Prominence of auditory symptoms, including hearing loss, tinnitus, and ear pain in diplomat reports,

typify reports of injury from pulsed RF/MW. Presence of variable additional symptoms of protean character

that differ markedly from person to person, with a relative emphasis on sleep disturbance, headaches, and

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11

cognitive problems; plus presence in smaller subsets of vision, balance, and speech problems are also

characteristic. Affected persons in both groups report sensory symptoms of pressure and vibrations. Persons in

both groups show evidence of brain injury. Reports in both indicate that some persons had prior head injury,

and brain injury may be a predisposing factor for, as well as a consequence of, RF/MW injury11,34

. Both show

varying rates of symptom persistence. How subsequent natural history will compare, for diplomat symptoms

that might follow more intense discrete exposure (a more intense exposure may produce problems in persons

who need not have relative vulnerability), vs follow repeated less intense ones (producing symptoms, evidence

suggests, selectively in persons more vulnerable to free radical injury from RF/MW, at a level to which they

will likely have subsequent exposure), is not known.

Fit with Literature:

Evidence for health effects of RF/MW is not new47,77-79

. By the early 1930s, studies were citing compatible

symptoms in radio amateurs and shipboard radio operators77

. By 1971/2 a Naval report bearing over 2300

citations, many from Russia and Eastern Europe, documented health effects of microwave/RF/MW,

emphasizing “non-ionizing radiation at these frequencies”80

. Contrary to claims by industry-affiliated parties,

copious evidence documents that radiation that is not “ionizing” can also cause health effects. Entire sections

of the 1971/2 report were devoted to each of a number of the symptoms that diplomats are now reporting,

including insomnia, headache, fatigue, cognitive problems, and dizziness80

. Injury from nonionizing radiation

occurs also without measurable heating – nonthermal radiation81-83

. Indeed, oxidative stress, which mediates

nonthermal effects, also mediates thermal effects; and melatonin, which defends against oxidative RF/MW

injury, also defends against so-called thermal injury84-88

. Moreover, other sources of heat do not produce the

same so-called “thermal” damage that RF/MW does47

: What are deemed thermal effects may be among the

manifestations of oxidative injury. While a low percentage of individuals experience overt symptoms from

usual RF/MW, the absolute number may be vast: the fraction with electrosensitivity/ electromagnetic illness

has been estimated at between 1 and 5%, and apparently rising37,89-92

.

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12

Limitations:

Features of diplomats’ experiences rely on media reports and one published neurological evaluation. We did

not examine diplomats; however, in conditions with highly distinctive characteristics, the history is often the

most important factor in the diagnosis, and diplomats’ reports bear highly distinctive characteristics. The close

matching of these distinctive characteristics to those of persons with health problems arising in apparent

relation to pulsed RF/MW, provides a basis for concern that RF/MW exposures may underlie diplomats’

symptoms and health conditions.

A tremendous number of physicians and scientists and entities and scientific studies and government reports, in

many nations, over many decades, have identified that RF/MW causes symptoms consistent with the spectrum

now described for diplomats. Scientific “skepticism” about RF/MW health effects is well represented in the

literature, but is of the industry-fueled stripe (think tobacco): Effects of conflicts of interest on research results

(as well as on funding, regulatory agencies, legislation and academics) vis a vis RF/MW, has been repeatedly

documented and decried93-97

, and evidence of this influence parallels evidence of potent impact of conflict of

interest in medicine more generally98

. In one illustrative analysis, studies of health effects of cell phones that

were funded exclusively by industry were least likely to report a significant effect. Relative to studies funded

exclusively by public agencies or charities, the odds ratio was 0.11 (95% CI 0.02-0.78)93

– that is, the odds

were ~a tenth as great for a significant finding in a study in purely industry funded studies. The finding was not

materially altered when analysis was adjusted for factors like study quality. Richard Smith, then Editor in

Chief of the BMJ (the British Medical Journal) penned an article “Conflicts of interest: How money clouds

objectivity.” Responding to evidence tying study results on a different lucrative product (tobacco) to conflicts

of interest (often undisclosed), he suggested that “far from conflict of interest being unimportant in the

objective and pure world of science where method and the quality of data is everything, it is the main factor

determining the result of studies”99

.

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Conclusions/Implications:

Numerous highly specific features of diplomats’ experiences and symptoms fit the hypothesis of RF/MW

injury. To distinguish between sonic and microwave hypotheses, earplugs can be issued to diplomats for use in

candidate episodes (e.g. strange noise plus ear pain): earplugs will mute sonic sources (caveat: a sound like

crickets chirping may in fact be crickets chirping), but not microwave ones (which may even be intensified).

Monitoring for culpable radiation sources must sensitively capture pulsed RF/MW, including that which may

be used only on an intermittent basis. It should encompass the 2.4-10,000MHz range in which the Frey effect

has been reported. Perhaps attention to diplomats’ plight can ignite awareness of the many others affected by

similar problems. Meanwhile, research already documenting compatible health effects of RF/MW in a

subgroup, may inform those caring for diplomats, and those in pursuit of causative devices.

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Table 1. Features of Noises Reported by Diplomats during apparent inciting episodes. Though “sound” refers to air pressure waves, we will refer to what diplomats “heard” as (perceived) sound. Diplomats’ Reports Compatibility with RF/MW

Strange noises were heard by

many “of the 24 ‘medically

confirmed’” affected US

diplomats1, during what were

perceived as inciting episodes10

.

Sound ordinarily results from air-pressure waves (which are “longitudinal” waves – variation occurs along the direction of travel of the

wave); whereas radiation arises from electromagnetic waves (which are transverse waves – variation occurs perpendicular to the

direction of travel of the wave). In each case, a “frequency” is defined by the number of “cycles” of the wave (that pass, say, a given

point) per second, for the respective wave type.

Though electromagnetic signals are not themselves sound, RF/MW can lead to perceived noises via the so-called “Frey effect”45

(aka

microwave hearing, aka RF hearing).

A 1976 Defense Intelligence Agency report stated “Sounds and possibly even words which appear to be originating intracranially can be

induced by signal modulation at very low average-power densities”78

.

A 1994 Air Force Materiel Command report stated, based on knowledge at the time, that “Individuals exposed to pulsed RF/MW

radiation have reported hearing a chirping, clicking or buzzing sound emanating from inside or behind the head. The auditory response

has been observed only for pulsed modulated radiation emitted as a square-wave pulse train. The pulse width and pulse repetition rate

are factors that appear to determine the type of sound perceived.... James Lin… reports that the sensation of hearing in humans occurs

when the head is irradiated at an average incident power density level of about 0.1 mW/cm2 and a peak intensity near 300 mW/cm2.

Auditory responses have been observed for a frequency range of 200-3000 MIHz and for pulse widths from 1-100 s”47

.

The frequency range within which sounds can be heard was broadened by 2003: it was reported that sounds can be perceived by persons

exposed to RF/MW in the 2.4-10,000MHz range45

. It was noted that the same frequency did not produce the same sound, from person to

person.

Not all diplomats heard

noises10

.

Ability to hear RF/MW-induced “sounds” (using the term to refer to the perception, not the stimulus) at all depends on individuals’ high

frequency hearing45

, as well as on low ambient noise45

.

Among those who heard noises,

the noises reported differed

markedly for different

diplomats5.

In RF hearing/ microwave hearing, the primary pitch heard (i.e. the perceived sound frequency), reportedly relates not to the radiation

frequency (cycles/sec), but to head dimensions45

. This comports with reports that different sounds were heard by different diplomats,

even if they were exposed to the same frequency (or conceivably frequencies, plural) of radiation. Of note, whether sound is perceived

from RF/MW is not governed by the average radiation level, but the energy in a single pulse. Injury to cells (in part through membrane

damage) is also materially greater with pulsed radiation100,101

. (Analogously, if a jackhammer hit very hard but very briefly at 2 minute

intervals, the low time-averaged pressure would not explain the effects produced.) Pulses of comparatively high intensity (relative to

typical exposures from technology) would have likely been necessary to produce the comparatively high prevalence of Frey-compatible

sounds, and of health effects reported among US diplomats.

The relatively high proportion of affected diplomats reporting Frey type noises, suggests the possibility of comparatively high intensity

of pulses; and frequencies within the designated 2.4-10,000MHz range.

These noises included a high

pitched “chirping,” ringing and

“grinding”8, 10

.

Frey “sounds” are “similar to other common sounds” “such as a click, buzz, hiss, knock, or chirp” – consistent with sounds that

diplomats reported45

.

In a 2007 Dutch survey completed by 250 persons with electrosensitivity (ES), queries related to noise included buzzing (reported by

n=96), hissing (n=80), strong low frequency sounds (n=55) and “sound of bells clanging” (n=28)102

. The term “chirping” (if there is a

Dutch equivalent) was not included among inquiries. Of note, the “strong low frequency sounds” are potentially consistent with the

“blaring, grinding noise” reported by a diplomat, next section (“blaring” indicative of “strong,” and “grinding” consistent with low

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15

frequency); while the “sound of bells clanging” is consistent with reports of diplomats who awoke to hear ringing “and fumbled for their

alarm clocks, only to discover the ringing {clanging} stopped when they moved away from their beds”5.

In the Maine Smart Meter survey report49

, comments by affected persons were included. Exemplars involving Frey noises included

these: {After} “72 Itron AMI smart meters {were installed} near me in my townhome complex… I hear a constant buzzing that is

driving me crazy. It keeps me awake and makes it hard to think. I am not sure if it is an actual sound, or if it is being generated inside

my head, because when I put my fingers in my ears I still hear it… In addition, at about every 15 or 20 minutes, a more intense whine is

added that lasts about 12-15 seconds, that hurts and gives me a mild headache which stops when the whine stops… When I go out into

the state and regional parks around me where there are NO smart meters for miles, I no longer hear the buzzing and my heart doesn’t

race” or in other cases “The noise I have in my head since smart meters is almost unbearable, sleep is at times impossible because it is

so loud”49

. “I became electrically sensitive almost immediately upon smart meter installation. My ears buzz, hum, and click constantly,

pressure in the head and ears,… agitation and irritability all since the PLC smart meter was placed on my home.. .I was able to vacation

where there was no smart meter installed and it felt as if a vice had been loosened from around my head”49

. A post regarding a woman

who removed her smart meter after becoming symptomatic repeated several times that the exposure caused her to hear “grinding”103

,

confirming this descriptor as among perceived RF/MW-hearing induced noises. Among those with ES who communicated with the

UCSD ES Survey group; for instance, one stated that in proximity to “electrosmog producing devices, “I hear sounds like beehives and

similar” (buzzing). Another stated: “The hissing in my ears is unbearable sometimes.” One wrote “annoying noise” was among other

symptoms.

The noises were heard primarily

at night10

.

Ability to hear RF/MW-induced sounds at all depends on low ambient noise45

. Night is generally a time of low ambient noise.

A sound that has been recorded

in Cuba and reported to be

“similar” to some sounds heard

is consistent with chirping of

crickets or cicadas (Lederman

& Weissenstein, 2017). Frey

effect sounds should not be able

to be recorded.

Recorded sounds, if similar to what was “heard” by some, need not be what was “heard”. (Just as Frey sounds are “similar to other

common sounds,” so those other common sounds can resemble the Frey sound.) The recorded sound does not cause symptoms in

listeners. The sound does not fit reports by other diplomats of either the character of the sound; nor of strict sound localization (such as

reports that when one moved from the bed, sound disappeared). Some diplomats had cited perceived sounds similar to crickets or

cicadas: the recorded noises were reportedly very similar to the chirping of crickets or cicadas that are abundant along the Northern

coast of Cuba104

. Perhaps what was recorded was (or included) crickets or cicadas. Since Frey effects can sound like crickets chirping,

presumably recordings of crickets chirping could resemble those Frey effect sounds.

(Those deploying causative devices could of course capitalize on misguided sonic hypotheses to lead the US astray, by adding a

recorded sound resembling Frey sounds; however there seems little need to postulate this.)

There was apparent “laserlike”

localization of sounds in some

cases.

For diplomats, “…at least some of the incidents were confined to specific rooms or even parts of rooms with laser-like specificity,

baffling U.S. officials who say the facts and the physics don’t add up”10

.

One incident was described in media as follows: “The blaring, grinding noise jolted the U.S. diplomat from his bed in a Havana hotel.

He moved just a few feet, and there was silence. He climbed back into bed. Inexplicably, the agonizing sound hit him again. It was as if

he’d walked through some invisible wall cutting straight through his room. Soon came the hearing loss and speech problems…”10

.

In claims that “the facts and the physics don’t add up”5, it was the physics of sonic devices that are inconsistent. The physics of EMR is,

to the contrary, compatible: lasers are themselves focused EMR. Tautologically, EMR can be focused in “laser-like” fashion.

Within the room or parts of

room where sounds were heard,

the sound follows the listener11

.

A diplomat reported that “’a really odd loud noise that seemed to follow him in the room’”11

. Frey “sounds” are also reported to follow

the person, often perceived as slightly behind the head, regardless of the body orientation relative to the source of radiation45-47

. (In other

cases “sounds” are perceived inside or above the head45,105,106

.

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16

Table 2. Symptoms and Signs.

Diplomats’ Symptoms

and Signs

Compatibility with RF/MW

I. Auditory Symptoms

are Distinctively

Prominent

Auditory symptoms are prominent in reports of diplomats’ experience, including ear pain or pressure41

, sometimes within minutes of the

perceived attack1, tinnitus

5,6,9,10,40 and hearing loss

9,10,15,17,39,41, 42. This, coupled with the strange noises in diplomats’ reports, likely launched the

sonic theory. These idiosyncratic features are key to winnowing potential causes. Symptoms like headache and fatigue arise with many

exposures and in many conditions. New onset of tinnitus and hearing loss is far more distinctive. (It is particularly so in the context of the

spectrum of other reported symptoms and effects, and in the context of characteristics of instigating episodes.)

These distinctive auditory problems are similarly prominent in people reporting symptoms from RF/MW48,51

.

Tinnitus and hearing loss were cited by 80% and 34% respectively in the UCSD survey of 202 individuals with current symptoms from EMR,

with pulsed RF/MW causing symptoms in the vast majority52

.

“Initial” symptoms were reported to include tinnitus in 50%, ear pain in 30%, and hearing loss in 11%.

Case descriptions shared by affected individuals underscore auditory effects. From the UCSD survey: “I bought a Kindle W-Fi. I charged it not

realizing the default setting was ‘on.’ After 5-10 minutes exposure, I became nauseated, had a headache, loud tinnitus… and was dizzy. I turned

the Wi-Fi off and the symptoms completely resolved in 5-10 minutes”52

. A description by former educator Brinchman characterizes her abrupt

development of headaches and hearing loss following introduction of pulsed RF/MW-emitting smart meters to her (and her neighbors’)

homes107

.

Similarly, physicians and physician groups that assessed patients with health effects from RF/MW and recognized the connection, also highlight

effects on hearing. A psychotherapist in Germany with a longtime practice described a new group of patients with a physiological illness profile

encompassing organic brain disease, with constellation of symptoms compatible with other reports of RF/MW injury. She was the one to

discern the tie between patients’ symptoms and their proximity to RF/MW sources (a connection that her patients had often missed – obviating

nocebo effects as a source – see Table 4), and to note recovery with removal from those sources108

. She describes “sudden hearing loss” as

among the symptoms (in addition to sleep problems described as “almost ubiquitous,” headache as extremely frequent, also noting fatigue,

cognitive problems, tinnitus, etc)108

.

A group of 114 physicians , referencing their analysis of medical complaints of 356 people in Oberfranken, signed an Open Letter to the Prime

Minister of Germany in 2004 (referred to as the Bamberg Appeal), stating “The pulsed high frequency electro magnetic fields (from mobile

phone base stations, from cable-less DECT telephones, amongst others), led to a new, previously unknown pattern of illnesses with a

characteristic symptom complex”109

. Prominent and repeated mention is made of hearing loss: “People suffer from one, several or many of the

following symptoms: Sleep disturbances, tiredness, disturbance in concentration, forgetfulness, problem with finding words, depressive mood,

ear noises, sudden loss of hearing, hearing loss, giddiness, nose bleeds, visual disturbances, frequent infections, sinusitis, joint and limb pains,

nerve and soft tissue pains, feeling of numbness, heart rhythm disturbances, increased blood pressure episodes, hormonal disturbances, night-

time sweats, nausea… It is no way only a subjective sensitivity disturbance. Disturbances of rhythm, hearing problems, sudden deafness,

hearing loss, loss of vision, increased blood pressure, hormonal disturbances, concentration impairments, and others can be proved using

scientific objective measures”109

(emphaes added). {Note also the mention of “ear noises” (the Frey Effect).}

Some studies that experimentally examine effects of RF/MW on hearing show effects, though not all do. (See Table 4 for discussion of

“inconsistent” effects.) A material consideration is that evidence is consistent with a vulnerable subgroup.

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17

One experimental study in humans found that 60 minutes of close exposure to EMR from a mobile phone “had an immediate effect on HTL

{hearing threshold limits} assessed by pure-tone audiogram and inner ear (assessed by DPOAE) in young human subjects. It also caused a

number of other otologic symptoms”110

.

Of note, melatonin – which can be depressed by EMR (see Table 4) and is low in those with EHS33

– protects against oxidative radiation injury

(Table 4) – including to the inner ear111

.

Pulsed RF/MW (more than continuous) has been shown to increase tympanic temperature, even when, for instance, colonic temperature is not

increased112

. Since blood flow is critical for cooling, and oxidative stress leads to endothelial dysfunction and may compromise blood flow,

affected individuals (see below, by hypothesis those with greater oxidative stress effects) may experience greater impairment in blood flow – so

less cooling, and also, impaired delivery (via impaired bloodflow) of oxygen, glucose, other energy substrates as well as antioxidant defenses).

The downstream effects of oxidative stress (e.g. apoptosis, inflammation etc – see below) and impaired cell energy/ mitochondrial dysfunction

(cell dysfunction and death) may contribute to auditory pathology.In a study examining the histopathology of cochlear nuclei of rats “exposed

continuously for 30days” to “a GSM-like 2100MHz EMF” “with a signal level (power) of 5.4dBm (3.47mW) to simulate the talk mode on a

mobile phone,” compared to a control group of rats not similarly exposed, “an increase in neuronal degeneration and apoptosis in the auditory

system“ was observed in the RF/MW exposed group113

. “The histopathologic analysis showed increased degeneration signs in the study group

(p=0.007). In addition, immunohistochemical analysis revealed increased apoptotic index in the study group compared to that in the control

group (p=0.002)”113

. In another animal study, “a prominent effect of EMS {electromagnetic stimulation} was … severe cochlear damage and

permanent sensorimotor hearing loss in experimental animals”114

.

II. Symptoms are

Protean

Beyond the auditory symptoms, the profile of symptoms in diplomats varies from person to person: Different people report markedly different

symptoms5. It was said that “The symptoms and circumstances reported have varied widely, making some hard to tie conclusively to the

attacks”115

; and “The cases vary deeply: different symptoms, different recollections of what happened. That’s what makes the puzzle so difficult

to crack”5. Reported symptoms encompass sleep problems

6,17,42, headaches

6,10,15,42, cognitive problems

10,42, nausea

10, fatigue

6, and dizziness

10,15.

Similar concerns had been raised with RF/MW injury. As noted by Dr. Aschermann (translated from German): “in the Deutsche Aerzteblatt

(official journal of the German medical association – Bundesaerztekammer) did an article ask the incredulous question: How could so many

different symptoms possibly be attributed to one common underlying mechanism?”108

.

Despite the protean character of symptoms, multiple survey studies verify that a strikingly reproducible suite of protean symptoms are

reported, in setting after setting, in people citing development of symptoms in response to EMR including RF/MW (Table 3). The profile of

symptoms is strongly similar from study to study, with sleep/fatigue, headache, and cognitive problems commonly topping the list, auditory and

visual symptoms, dizziness and nausea figuring in it.

A similar primary list (sometimes augmented with a few additional symptoms – often including heart rhythm problems) is mentioned in other

settings. The analyses of 65 patients by Dr. Aschermann cite symptoms of learning concentration and behavioral problems, headaches,

insomnia, exhaustion, hearing loss, tinnitus, hearing loss, dizziness, nerve and soft tissue pain, “inner agitation”, as well as arrhythmia

problems108

. In the 2004 Bamberg appeal signed by 114 physicians to the then German Prime Minister, based on analysis of 356 patients: “The

pulsed high frequency electro magnetic fields (from mobile phone base stations, from cable-less DECT telephones, amongst others), led to a

new, previously unknown pattern of illnesses with a characteristic symptom complex. People suffer from one, several or many of the following

symptoms: Sleep disturbances, tiredness, disturbance in concentration, forgetfulness, problem with finding words, depressive mood, ear noises,

sudden loss of hearing, hearing loss, giddiness, nose bleeds, visual disturbances, frequent infections, sinusitis, joint and limb pains, nerve and

soft tissue pains,”, also nausea, and “feeling of numbness, heart rhythm disturbances, increased blood pressure episodes, hormonal disturbances,

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18

night-time sweats.…The symptoms occur in temporal and spatial relationship to exposure. It is no way only a subjective sensitivity disturbance.

Disturbances of rhythm, hearing problems, sudden deafness, hearing loss, loss of vision, increased blood pressure, hormonal disturbances,

concentration impairments, and others can be proved using scientific objective measures”109

.

Among individuals participating in a physiological provocation study examining heart rate variability with RF/MW, among 25 patients 40% of

whom believed themselves to be moderately or severely electrosensitive: “The most common symptoms of exposure to electrosmog, as

identified by this group of participants, included poor short-term memory, difficulty concentrating, eye problems, sleep disorder, feeling unwell,

headache, dizziness, tinnitus, chronic fatigue …”116

.

Of note, the same symptoms also arise in the vulnerable subgroup of persons who develop health problems following other exposures that share

a documented ability to cause mitochondrial impairment and oxidative stress55,57,117-119

. However, the profile – which symptoms dominate –

differs from exposure to exposure, based on factors such as what part (s) of the body the exposure may differentially reach, and whether

additional mechanisms of injury are involved that potentiate damage to one domain.

Sleep and auditory effects are clearly disproportionately represented, in diplomats and with RF/MW exposure, relative to their prevalence

following other exposures that cause oxidative stress. The strong effects on sleep may relate to depressions in melatonin that can be produced

with EMR/ RF/MW (see Table 4). Auditory effects are addressed above.

A 1990 study commissioned in response to a petition by residents who cited adverse health experiences from a shortwave radio transmitter in

their small town of Schwarzenburg, funded in part by Swiss Telecom, reported that sleep disruption in association with transmitters related

directly to the EMR field strength of the transmitter, and affected 55% of those over age 4548,68

. (There the denominator is not restricted to those

who were symptomatic.)

A 1994 Air Force Materiel Command reports that “Pulsed RF/MW radiation was reported to have an analeptic effect in animals. Experimental

results presented by R.D. McAfee in 1971 showed that anesthetized animals could be awakened by irradiation from a pulsed 10 GHz RF/MW

source…Experiments conducted on rats showed that these animals were aroused from states of deep sleep by irradiation”47

.

The prominence of auditory effects (see above for more on these symptoms) may relate in part to absence of a skull structure to protect the inner

ear, producing an incident stimulus that is of greater effective intensity.

The coherence of symptoms in response to RF/MW, with findings in Cuba (and China) diplomats, adds further support to the case for a

common cause within each group – and across the two groups.

III. Symptoms include

some that are

(potentially)

objectively

measurable:

Speech9,10,42

;

Vision42

; and Balance10,

42; and

Nose bleeds in some9.

The symptoms reported in media and the Swanson article for diplomats – extending to the more specific, like dizziness/balance, vision and

speech problems – are also reported in survey studies of those affected by RF/MW (Table 3).

Speech problems, mentioned in diplomats, were also among symptoms elicited and reported in a survey study examining effects of RF/MW

following “smart meter” introduction in Australia48

.

Reported cases illustrate speech problems arising following RF/MW exposure. In a case referenced in the LA Times, a woman reported that if

someone fails to turn off their cellphone on entering her home, she gets symptoms within 2 hours; “‘After four hours I can’t speak anymore””32

.

In a case described in a 2015 Australian presentation on ES120

: “Within hours, it felt as if someone had tied a thick rubber band around her head.

Then came nausea, fatigue, ringing in her left ear – an onslaught of maladies all at once, and she had no idea why…A week or two into the job,

whatever was affecting her wasn’t abating, and before long her speech became so jumbled that she couldn’t form a complete sentence in front of

an audience…She went outside to inspect the place and found no fewer than 17 new ‘smart’ electricity meters strapped to the side of the

building.”

In a case reported to UCSD investigators, new onset right-sided ear pain and hearing loss attended the inciting episode (seated for six hours,

unknowingly, directly across the wall from a bank of multiple smart meters for a building, slightly toward her right), along with vis-like

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19

headache, concentration problems, and two nights of no sleep (followed by chronic lesser sleep impairment), and, abating over months,

continued to be triggered – always exclusively or predominantly on the right side – by previously tolerated RF/MW exposures thereafter. Many

months later left ear predominant ear symptoms developed for the first time. A bank of smart meters was identified to the left of where she had

sat hidden by plants so missed in an initial reconnaissance. That occasion, the only one with left predominant ear and hearing symptoms, was

accompanied by speech difficulty, that resolved over about a week. In these two cases, aphasia was associated with left predominant ear

symptoms. {Broca’s area, damage of which leads to expressive aphasia, is left prefrontal.} It is an empirical question whether left-predominant

auditory involvement will prove more often tied to affected speech.

Balance is multifactorial, involving e.g. vision, muscle strength, and vestibular function. In some media reports of diplomat health, the term

vertigo is used40

. Balance and vestibular testing were performed in diplomats41

. Clinical examinations/objective measures raised concern for

balance problems in 81% (higher than percent reporting subjective dizziness or balance problems)41

.

Vestibular function involves the same (eighth) “cranial nerve” as hearing. Vertigo, hearing loss and tinnitus can arise (as adverse effects) as a

triumvirate121,122

. Dizziness more generally, in contrast to vertigo, is a nonspecific finding, that arises with many forms of brain insult –

including brain hypoperfusion (low blood flow). Of note, cerebral hypoperfusion has been reported in persons with symptoms following

RF/MW33

.

In some surveys of RF/MW affected individuals, dizziness and balance are queried together48

; other surveys only use the term dizziness.

Individual reports of balance and dizziness problems were included among participant narrative reports in the Maine survey. E.g. “‘Balance

problems have worsened since installation of the smart meter, leading to several falls’”49

. “‘I could not understand the dizzineness which was

scary. I actually thought I had a brain tumor all of a sudden’”49

. The Cuba diplomat study considered nausea as a vestibular symptom41

. Though

it need not necessarily be, it was linked to dizziness in some RF/MW/EMR affected cases: “‘Daily nausea and dizziness’”49

.

Loss of balance, with dizziness and disorientation, was identified as one of six clusters of symptoms seen in each of two smart meter surveys

from different nations, with the clusters represented nearly in the same order (1. Sleep disruption; 2. Headache; 3. Ringing or buzzing in ears; 4.

Fatigue; 5. Loss of concentration, memory or learning ability; 6. Disorientation, dizziness, or loss of balance)123

.

Vision: Vision is affected by oxidative stress and mitochondrial impairment (see Table 4, mechanisms)124-129

, not just to the eye but to cortical

systems involved in vision130

. Effects of these mechanisms include optic nerve damage129,131,132

, “age” related macular degeneration125,128,133-137

,

retinal thinning138

, and cataracts139-143

. Where brain swelling ensues (see Table 4), this can affect the shape of the lens, affecting vision.

Effects of RF/MW on the eye and on vision have long been reported47,144-150

. Particular attention has gone to effects on the lens and on cataracts.

RF/MW, via oxidative mechanisms, promotes aging of the lens which can lead to cataracts. Cataracts have been a reported complication –

sometimes in young people – among persons working with microwave radiation47, 144-147

. A Swiss study (Hassig et al, 2012) documented

increased cataracts in calves born near cell towers: “We examined and monitored a dairy farm in which a large number of calves were born with

nuclear cataracts after a mobile phone base station had been erected in the vicinity of the barn. Calves showed a 3.5 times higher risk for heavy

cataract if born there compared to Swiss average. All usual causes such as infection or poisoning common in Switzerland could be excluded.”

Vision problems are reported in RF/MW affected persons. In a study in Spain, in persons in proximity to two GSM (Global System of Mobile

Communications) cell tower base stations, analysis of the closer group – with exposure in the range 0.25-1.29V/m2, in a model adjusted for age,

sex, and distance, showed that vision problems were elevated with an odds ratio of 5.8 (95% CI 1.7-19.8, p= 0.005)151

.

11% reported problems with eyes or vision in the Australian smart meter study; since this includes respondents who are unaffected, rates are

lower than in purely symptomatic individuals48

. 26% of survey participants reported eye/vision problems in the Halteman smart meter impacts

survey51

. Vision problems were reported by 17% as “severe and new,” by 38% as “moderate and new,” and by 12% as “severe and worsened”

in the Maine smart meter survey49

.

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20

An assessment of neurological problems in US diplomats in Cuba underscores potential importance of eye movement dysfunction41

– which is

also tied to oxidative and mitochondrial mechanisms152-160

.

Epistaxis (nosebleed): In a study in Selbitz, Bavaria, nosebleed was significantly more frequently reported (p=0.01) in those <200m from a cell

phone base station than 200-400m away161

. Nosebleed was a reported symptom in each of several surveys of ES and symptoms associated with

RF/MW, including in a study of smart meter symptoms48,49,51,52

(Table 3). The Bamberg Appeal (on behalf of 114 physicians referencing

assessment of medical complaints of 356 people with symptoms from cell tower base stations and DECT phones in their homes in Oberfranken)

noted the more characteristic RF/MW symptoms (above) as well as nosebleed109

.

Comments from participants in survey studies include the following: “Severe headaches, gushing nosebleeds for the first time ever...They all

went away when the smart meter was removed”49

. “After the first day I was getting bloody noses and not understanding”49

. Another stated

“Nosebleeds, nausea, dizziness, ... ringing ears and intermittent strong agitation… When I am away from wireless devices the symptoms

subside”49

. And, another, “Had it not been for the severe nose bleeds I’m not sure I would ever have found out what was causing my health

problems”49

.

IV. Peculiar Sensory

Symptoms of

“Vibration” and

“Pressure” are

Reported

“Associated sensory symptom” of “pressure” or “vibration” were reported in 43% and 14% respectively, in a neurological evaluation of

diplomats41

.

The distinctive sensory symptoms of “pressure” and “vibration” are also reported by subsets of those who report symptoms from RF/MW.

Neither were commonly elicited as symptoms in surveys. However, some surveys listed head pressure separately from headache, and in some

cases it was more frequent. Eye pressure (Halteman, 2011) and ear pressure (Conrad & Friedman, 2013) have also been reported in surveys of

RF/MW/EMR affected persons. The UCSD ES survey did include “internal pressure,” which was reported as a symptom in 71% of participants

who cite symptoms from EMR/RF/MW52

.

Spontaneous reports of vibration symptoms by different EMR/RF/MW affected persons, shared in a different survey study, include the

following: “I experienced internal shaking and vibrating throughout my body” (along with sleep, mood, headache, head pressure, and other

problems, after smart meter installation)49

; “I can’t think clearly, or find words when speaking; my body feels like it is vibrating”49

; and “have

uncontrollable jelly-like quivering throughout whole body”49

. In online comments posted in response to articles on related topics, in which

persons describe their ES symptoms, statements include “vibration through my body”162

; and “I have a smart meter on my house and I have

been experiencing strange vibrations when I watch TV or use the computer”163

. An email to us from an affected patient (9-2017) sharing her

symptoms stated: “Which feels like my brain is vibrating and spinning at night – and my tinnitus gets much worse…”.

V. Brain Swelling is

Reported

in Some Diplomats5,9,

19.

1. RF/MW may alter blood-brain barrier function via oxidative stress.

a. An analysis reported that of 100 peer reviewed studies examining whether low intensity RF/MW causes oxidative stress, 93 found that it

did60

.

b. Oxidative stress disrupts the “blood-brain barrier”164-176

.

c. Consistent with this, blood-brain barrier disruption has been shown in multiple studies with RF/MW172-174,176-179

. Other studies have not

shown blood brain barrier effects180-186

. Studies vary in many respects (e.g. exposure duration, EMR exposure characteristics, model (in

vivo vs in vitro, animal, age), delay between exposure and blood-brain barrier assessment, blood-brain barrier assessment used, etc. The

blood-brain barrier is functional, and barrier function need not be affected for all substances equally.)

d. Since genetics of oxidative stress management67

, and levels of key antioxidants33

, relate both to RF/MW injury and to oxidative stress,

these factors – together with specifics of the RF/MW exposure – may guide blood-brain barrier disruption with RF/MW.

e. A study that examined gene expression in the brain of rats exposed to GSM radiation, radiation that encompasses the multiple frequencies

and pulsed waveforms present in GSM exposures, identified altered gene expression of a marker of blood-brain barrier function187

.

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21

2. Altered blood brain barrier can lead to brain edema and “malignant brain edema”188,189

. (Oxidative stress associated blood brain barrier

disruption is, for instance, thought to underlie neuroleptic-induced cerebral edema190

.)

3. Perceived head pressure occurs with brain swelling, and is reported by many with ES. As also noted above in relation to the sensory symptom

of “pressure,” some surveys collate head pressure separately from headache (which, in some studies, it surpasses)48,49,102

; one survey included

eye pressure51

; and in one, several participants spontaneously reported ear pressure49

. Communications to the UCSD ES study included write-in

comment “brain feels like it’s swelling”52

. One man with severe ES who communicated with the UCSD study group, who shared documentation

of his approval for Social Security disability for his ES, reported that the severe brain swelling he experienced in response to EMR had led an

eyeball to be pushed from the socket.

VI. Findings are

Reported to be

Compatible with

Traumatic Brain

Injury40,43,191-194

.

1. Based on findings in an fMRI study of electrosensitive individuals it was stated: “the differential diagnosis for the abnormalities seen on the

fMRI includes head injury”34

.

2. 6 of the 10 ES individuals assessed reported prior head injury34

. However, four did not, and also showed evidence of brain injury. Moreover,

prior head injury is reported to also be present in at least some, but an unstated fraction of, affected diplomats11

.

3. Head injury could predispose to ES: Head injury, like RF/MW, promotes oxidative stress and blood brain barrier disturbance – and melatonin

(which is low in those with ES) protects from these effects in head injury195-198

, as it protects against injury from radiation111,124,141,199-227

– and

from RF/MW228-240

.

4. One RF/MW affected who communicated with the UCSD study group indicated his ES was precipitated by a serious occupational head

injury. (He also had occupational exposure to EMR, but until the head injury it had not bothered him.)

5. Given findings consistent with low melatonin in those with ES33

, this condition (and/or common cause) may also predispose to more

significant damage from a given impact and character of head injury – so greater likelihood that a given head impact causes problems, and is

remembered and reported as a head injury.

6. The study did not report presence/absence of features indicative of greater severity of head injury – such as loss of consciousness, or

symptoms or sequelae. Both because of this and point 5, there is not clarity about whether prior head impacts were in fact greater in number or

intensity than in the general population. But as above, it might be expected that past head injury would be a risk factor.

7. ES symptoms are sometimes experienced as similar to a head injury. For instance, an affected Rhode Island teacher likened effects

experienced with RF/MW to a concussion241

.

Just as it is important to avoid even minor head trauma following traumatic concussion, until healing has occurred, so avoidance of RF/MW (or

more generally EMR) aggravation may prove important following pulsed RF/MW injury: radiation injury may be cumulative and in addition to

the intensity-duration profile, the interval between exposures may be important in the clinical course145

.

VII. White Matter

Abnormalities are

Reported44

in some

diplomats.

In diplomats: “Medical testing has revealed that some embassy workers had apparent abnormalities in their white matter tracts that let different

parts of the brain communicate”44

.

1. White matter changes were observed in some with ES, in the fMRI study of persons affected by RF/MW/EMR34

.

2. Oxidative stress and mitochondrial dysfunction (to which RF/MW can contribute, Table 4) are associated with white matter injury242-248

.

Among potential mechanisms, oxidative stress increases vulnerability of proteins (and lipids, DNA, RNA, etc) to autoimmune attack, which can

include attacks on myelin249-258

.

Indeed, antibodies directed to O-myelin were reported in a subset of the 675 persons with ES that were included in a French study33

, affirming

one mechanism by which white matter changes might occur.

3. Following GSM radiation exposure (study cited previously), examination of gene expression in rat brain showed alterations in myelin-related

products (myelin-related glycoprotein)187

.

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22

Table 3. Symptoms in Diplomats: Comparison to Symptom Rankings in Survey Studies that report symptoms with EMR, or in those with

ES. Percentages are given for diplomats (chosen for being symptomatic); and rankings for studies of persons reporting symptoms with EMR/RF/MW

(not restricted to acute stage). Cuba Diplomats Australia

2014

US

2011

Wireless

Utility

Meter

Safety

Impacts

Survey

US*

2013

Maine

Smart

Meter

Health

Effects

Survey &

Report

France

2002

Japan

2012

US*

2015

Nether-

lands

2007

Sweden

2006

Finland

2013

Turkey

2017

Citation Study of diplomats41

News media

Lamech48

Halteman5

1

Conrad49

Santini259

Kato50

Golomb52

Schoonev

eld102

Johansson37

Cites

Swedish

Language

article260

Hagstrom29

Durusoy26

1

EMR- or

ES-related

characteri

stic

N/A Smart

meter

exposure

Smart

meter

exposure

Smart

meter

exposure

Proximity

to cell

phone

base

station

ES ES ES ES, acute

phase

ES, acute

phase

Cell

phone use

–

symptoms

during

Sample

characteri

stics

~24 US and 2 Canadian

diplomats to Havana

reporting symptoms

attributed to “health at-

tacks” in news;

(24 US embassy

community members

with neurological

findings often seen after

mild traumatic brain

injury/concussion41

)

92

Residents

of Victoria,

Australia

after

exposure to

smart meter

radiation

318 US

Responde

nts from

28 states

210

Respond

ents,

68% ES

(142) †

530

People

living near

cellular

phone

base

stations

75

Japanes

e with

ES or

sensitiv

e to

EMF

202

Persons

with

current ES

250 Dutch

responden

ts with ES

22 with ES

ranked

symptoms.

Most

common

were listed

(not

ranked)

194 with

ES

2150

students in

26 high

schools in

Turkey.

All have

symptom

Yes No No No No Yes Yes Yes Yes Yes No

JA0606


23

s

Symptom

Rankings

Two

rankings

given:

for

severe or

moderate

and new/

severe

and new

Sleep (86%) 41

Also:6

#1

#1

#4/ #1

#3

#4

76%

#1

94%

#5

Yes #2 #6

Headache (81%) 41

Also:5,6,15

Also: (Lederman,

Weissenstein, Lee et al.,

2017; Panetta, 2017;

Robles & Semple,

2017b)

#2

#3

#1/ #3

(pressure

in head;

headache

is listed

separatel

y and

would

be #5/#5

#2

#2

81%

#2

88%

#7, #9,

#10

(separated

into 3

questions;

#10 is

pressure

in head;

#7 is

numb

feeling in

head)

Yes #4 #2

Cognitive (81%) 41

Also:6,19,262

#5

#5

#2/#4

#4, #7

#3

81%

#3

85%

#2, #13 Yes #7,#10 #4,#5

Stress

anxiety

irritability

67% irritability;

57% nervousness;

52% more emotional;

29% sadness

41

#11

#2

#8/#7

(agitation

)

#6

(irritabil-

ity)

#9 &

#10, for

“irritati

on” and

“anxiety

56% &

55%.

#6 in

“initial

symptoms

”,

irritability

45%

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24

Tinnitus (57%) 41

Also:5,6

#3

#4

#3/ #2

Not

queried

(except as

“hearing”)

#7

63%

#5;

80%

Not in

main list,

but by #

affected

in

auditory

list, #13

Not queried

Fatigue Not elicited ‡ 41

Mentioned in news

media6,41

)

#4

#6

#10/#9

#1

#1 (and

possibly

#5

“sluggis

h in the

head”)

85%

“Exhaus-

tion” was

a write-in

symptom

(Not

queried)

#1 Yes #6 #1

Dizziness

or balance

(67%§) 41

Also:5,6,15

#7

#7

#7/#7

#14

#6

64%

#4 Initial

49%

#11 Yes #12 #9

Vision

problems

(76%) 41

Also:42

#12

#8

#10/#11

#12

--- #8 in

Initial

Symptoms

38%

#6 ----- #13

(photosensi

tivity)

#10

Nausea 5,6,9

#9

#12

--- --- --- #9

“gastroint

estinal

symptoms

”

(64%)

(Nausea

not

separately

asked)

--- Yes

(“symptom

s from the

gastrointest

inal tract”)

#20 #15

Epistaxis

(nose

bleed)

not elicited 41

Mentioned in news/

#17

#13

#15 in

symptom

s that

intensifie

---- --- “Noseblee

ds” as a

write-in

symptom

---

(#12 is

“nose

problems”

---- ---- ----

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25

media:9

d. New

onset in

several

write-ins.

(not

queried)

)

Hearing

loss

(43%) 41

Also:6,9,15,17,39

#18 (with

ear pain)

--- --- #5 --- #11

34%

#3 --- --- #14

Speech

problems

Not elicited ¶ 41

Mentioned in:9

#30

--- --- --- --- ** --- --- --- ---

Comment †† ‡‡ §§ ¶¶ ¦ ¦ ¦

---- = Not queried

Surveys in the smart meter era were prioritized for inclusion; proximity of emitting devices to homes may make these more comparable to diplomat experience.

Studies of ES were also prioritized, as these focus on those who are symptomatic, providing symptom rates better suited for comparison to those in affected diplomats.

Other studies on similar themes report similar findings.

(An exception is that older studies from Scandinavia that focused on exposure to video display terminals from that time, report high rates of skin problems.)

For instance, a 2007 study of 85 persons living nearby the first mobile phone station antenna in Menoufiya governorate, Egypt reported that “The prevalence of

neuropsychiatric complaints as headache (23.5%), memory changes (28.2%), dizziness (18.8%), tremors (9.4%), depressive symptoms (21.7%), and sleep disturbance

(23.5%) were significantly higher among exposed inhabitants than controls: (10%), (5%), (5%), (0%), (8.8%) and (10%), respectively (P < 0.05).” Sleep, headache and

cognitive again topped the list in frequency263

.

Some studies focus not on ranking, but dose-effect/distance relation. For instance, in Selbitz, Bavaria, those within 200m of a cell phone base station were compared on

reported symptoms to those 200-400m away, and were found to report significantly more sleep problems, headache, concentration problems, “cerebral affections”,

depression, auditory/vestibular problems, visual problems, GI problems, dizziness, and nosebleed – also cardiovascular problems, joint problems, infections and skin

problems “ (p = 0.01” for dizziness and nosebleed, “p=0.001” for the rest)161

. A 2003 survey study of the “microwave syndrome” “in Murcia, Spain, in the vicinity of a

Cellular Phone Base Station working in DCS-1800MHz,” reported that symptoms included fatigue, irritability, headache, nausea, insomnia, depression, discomfort,

difficulty in concentration, memory loss, visual dysfunction, auditory dysfunction, dizziness (as well as several other symptoms)24

. These were more prevalent within 150m

of the station, relative to >250m, in most cases significantly so. It was noted that symptoms abated with removal from the RF/MW source24

. A follow-on study examining

rates of problems in relation to measured electric fields, and showed significance for 13 of 16 assessed symptoms, with symptom odds ratios as high as 59151

.

Our rankings do not include as a symptom, “Onset of Electromagnetic Hypersensitivity Syndrome” or “Aggravation of Electromagnetic Hypersensitivity Syndrome”. We

used the highest ranking if several cognitive queries were used (e.g. memory problems or concentration difficulties), or several head queries are used (e.g. headache, head

pressure, heat or strange sensation in head), and exclude later exemplars of the category in ranking the lower ranked items.

* There was no barrier to participation from outside the US, but participants are predominantly from the US

† 68% of participants had ES (N=142) of whom 63% felt certain their exposure to smart meter was responsible for initiating the ES. Of the 49 who were ES before smart

meter exposure, all 49 (100%) stated that smart meter exposure made their ES not only worse but “much worse”

‡ Though fatigue was not elicited, it is noted that a number reported a “good day bad day” pattern in which mental or physical exertion on one day led to exacerbation for

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several days.

§ Separates out balance (67%), dizziness (63%) and includes nausea (7%) in this category.

¶ Speech problems were not elicited but speech audiometry, speech therapy, speech pathology consultation are each mentioned totaling at least six references.

** Aphasia” was a write-in symptom (not queried).

†† 73% women; 93% over age 40; 43% over age 60; 78% from California; 49% characterize selves as EMF sensitive.

‡‡ The 1st number is severe or moderate and new; 2nd

number is severe and new.

Pressure in head and headaches were queried separately. The overlap is uncertain. The higher ranking (pressure in head) was used.

Concentration and memory were queried separately. The overlap is uncertain. The higher ranking (concentration problems) was used.

§§ Memory and concentration were queried separately, ranked #4 and #7 in the original. Combined might be higher. The higher ranking is used. This analysis provides

values at different distances. Orderings for the closest distance are used. Ordering shifts slightly with longer distances but in general, the more frequently reported

symptoms remain the more frequently reported.

¶¶ Ratings are based on (videotaped) Commonwealth Club slide presentation. Additional symptoms were elicited but not presented.

¦ Notes buzzing ears, hissing sounds, loss of hearing, strong low frequency sounds, ear aches, and sound of bells clanging in 96, 80, 64, 545, 38, and 28 participants

¦ ¦ This assesses acute symptoms. It also gives fractions who report those symptoms before the acute phase, but it is unclear whether someone who reports a symptom (say,

headaches, dizziness) before exposure, had those symptoms only occasionally.

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Table 4. Mechanism Considerations.

Oxidative

Stress –

mediated by

free radicals –

is involved in

RF/MW

injury

Oxidative stress refers to a kind of injury against which “antioxidants” relatively protect, in which “reactive oxygen species” or “free radicals” produce

changes/damage that can affect, for instance, lipids, proteins, DNA, and RNA.

Mitochondria, which are the primary source of energy for cells (and regulate many other phenomena such as steroid hormone production and apoptosis)

are a leading source and target of oxidative stress59,264-267

– that is, mitochondrial injury not infrequently accompanies oxidative stress, and has been

shown with RF/MW (see below).

RF/MW produces oxidative stress. As above, in an analysis of 100 studies examining if low-level RF/MW produced oxidative injury, it was reported that

~93 found that it did60

.

Oxidative stress – and mitochondrial dysfunction are implicated in the symptoms and health effects that have been reported by diplomats (and RF/MW

affected persons)127,138,139,268-300

.

For instance, oxidative stress is tied to tinnitus, antioxidants modestly alleviate it, and markers of oxidative stress in tinnitus are reported to be greater in

jugular blood (near the ear) than the more commonly measured brachial blood269,270,301

.

Two findings substantially cement a role for oxidative stress in RF/MW health effects.

First, persons who are “electrosensitive” (i.e. who experience symptoms at levels of radiation than many others tolerate) are significantly more likely to

harbor gene variants that confer less-avid protection against oxidative injury67

. This is an extremely important finding. People cannot manipulate their

genes in response to suggestibility, and did not know their genes when they reported their sensitivity status. This powerfully supports a causal role for

oxidative stress in the injury experienced.

Second, a French study in electrically and chemically sensitive individuals (93% with ES), found consistently low levels of a urinary melatonin

metabolite33

. Since melatonin is an antioxidant that protects against damage to many toxins – but that has been shown in numerous studies to be

particularly vital for defense specifically against oxidation injury due to radiation across the electromagnetic spectrum111,124,141,200-208,210,211,213,214,216-222,

224,225,227,302,303, including due to RF/MW

228-239,304, this dovetails with the aforementioned genetic data to compellingly support a role for oxidative stress –

and to show that that those with ES – those who experience symptoms with radiation that others tolerate – are also experiencing greater cellular and

subcellular injury from this radiation.

Many studies show the importance of antioxidant defenses – including but not limited to melatonin – in protection against RF/MW injury. For instance,

melatonin and to a lesser degree caffeic acid protect against cell phone induced oxidative stress in rats – and melatonin increased activity of other

endogenous antioxidant enzymes, superoxide dismutase (SOD), glutathione peroxidase (GPx) and catalase which were depressed with the cell phone

radiation236

. Melatonin protected against laryngotracheal oxidative injury from wireless (2.45 GHz) radiation in rats229

. Melatonin protected against skin

oxidative injury in an experimental mobile phone model in rats228

. Melatonin protected against 900MHz microwave radiation induced lipid peroxidation

in rats230

. Melatonin reversed the oxidative damage of microwaves to rat testes – including protecting testosterone level, sperm count, and protecting

against DNA fragmentation (a marker of cell death)232

. Melatonin protected against oxidative damage from cell phone radiation to rat brain238

. Melatonin

protects against oxidative damage from Wi-Fi to lens of rats239

. Vitamins E and C protect against “900 MHz radiofrequency-induced histopathologic

changes and oxidative stress in rat endometrium”305

. Ginkgo biloba protected against cell phones induced oxidative injury in rat brain306

. And so on.

Antioxidants work together, for instance, to recycle one another to the reduced form in which they are active as antioxidants.

The importance of antioxidant defenses in protection against radiation injury from RF/MW, extends what is well known for injury from radiation

throughout the electromagnetic spectrum, including so-called “ionizing radiation” (which includes gamma for instance, “A positive correlation was

found between GPx activity, glutathione content and cell survival following ionizing irradiation”307

. Glutathione depletion increased with gamma

radiation induced DNA damage308

and cell death309

. Glutathione determined the survival “shoulder” for x-ray radiation in hypoxic cells310

, and melatonin

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protected against x-ray induced lung injury217

. Melatonin protected against radiation induced cataract141

– and increased activity of other critical

antioxidant enzymes, SOD and GPx. SOD protected against fractionated radiation induced esophagitis (and reduced the effect of that radiation on

glutathione)311

. Melatonin protected against UVB radiation-induced oxidative skin injury222,223

; as did glutathione312

, and chocolate, which is rich in

antioxidant polyphenols313

. Melatonin has specifically been reported to protect the inner ear against radiation injury, in rats exposed to “radiotherapy” at

4-6KHz111

.

A role for oxidative stress in radiation injury transcends labels of “ionizing” vs “nonionizing”, “thermal” vs “nonthermal” radiation. For this reason,

those labels are of questionable utility in understanding radiation damage.

Radiation

may depress

melatonin –

moreso in

some – and in

part through

depressed

melatonin,

may depress

other

antioxidants

A number of studies report that EMR, including but not limited to RF/MW, can depress melatonin302,314-322

. Evidence suggests that (like virtually all

biological effects), a subgroup is more vulnerable323,324

. {Note that sunlight, which provides EMR of a kind “expected” evolutionarily, is well recognized

to govern (depress) melatonin, toward producing day-night and seasonal effects.}

Light (a portion of the electromagnetic spectrum) inhibits melatonin as part of establishing circadian and seasonal rhythms325-327

.. Evolution did not plan

for man-made radiation sources, and one hypothesis is that, in some people, such radiation sources may induce similar effects.

“EMF {electromagnetic fields} are known to affect Ca2+ homeostasis and suppress melatonin activity in a wide wavelength range. Ca2+ ions in

pinealocytes are involved in regulation of cAMP synthesis that mediates conversion of serotonin into melatonin. Their leakage from pinealocytes results

in a decrease of the cAMP level and thereby suppresses production of melatonin”328

. Long-term radar workers reportedly have increased serotonin and

depressed melatonin, consistent with this impaired conversion – and effects in the RF/MW frequency range329

. Electronic repair workers have also been

reported to have lower melatonin than controls, and more sleep problems330

.

Melatonin (and its derivatives) – though better known for effects on sleep – provide a critical antioxidant defense system that protects against toxicity of

an extraordinary array of toxins and conditions274,331-355,356-382,383-416

.

For this reason, to the extent that EMR does depress melatonin, it is expected to potentiate the array of adverse health outcomes tied to these toxins, and

other sources of injury.

Melatonin specifically protects against radiation injury at frequencies across the electromagnetic spectrum111,200-202,205,206,208-210,212-214,216-220,223,225,226,230,

233,238,239,304,417,418.

A study examining gene expression in rat brain reported that brain expression of N-acetyltransferase-1, the rate limiting enzyme in melatonin

production419

, had significantly reduced expression following 915 MHz GSM-consistent RF/MW radiation (encompassing pulsed RF/MW) in rats, fold

difference 0.48 ± 0.13, p < 0.0025187

.

Suppressed melatonin or sleep deprivation in turn increase damage to the pineal gland420

, which produces most of the circulating melatonin. Thus,

sufficiently depressed melatonin can beget still further depressed melatonin – and heightened vulnerability to injury from future EMR exposure.

Ability to sustain adequate melatonin production in the face of EMR/RF/MW, may be a critical determinant of pineal vulnerability. The pineal gland has

high antioxidant needs420,421

, and in absence of such protections is vulnerable to involution422,423

.

Age-related involution of the pineal gland may help to explain why more middle-aged persons are reportedly affected by ES than younger people424

,

though presumably younger adults may be more exposed to technology. {Middle-aged persons may, however, have had more years of EMR exposure.)

Melatonin supports levels and activity of other antioxidants, including in the setting of radiation exposures141,236,239

. Modest exposure to oxidative

stressors (including from radiation) in persons or animals or plants whose system is not overwhelmed, can lead to antioxidant upregulation – a

phenomenon called oxidative preconditioning, seen with many sources of limited oxidative stress, including limited exposure to radiation425

. In part

because of this, the net effect of an oxidant exposure on antioxidant levels depends on factors like intensity and duration of exposure, other oxidative

exposure (so, mitochondrial dysfunction state), and status of antioxidant defenses, as well as time from exposure to assessment. Some studies in some

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systems show antioxidant upregulation426

or mixed direction effects on different antioxidants239

, but many show depression of assessed antioxidants

following EMR exposures222,223,427,428

or specifically RF/MW exposure235,236,237,239,305,429-435,436

. Such depressions, coupled with melatonin depressions,

may enhance vulnerability to future EMR exposures – particularly where genetics provide for less effective variants of one or more antioxidants67

.

It is expected that mitochondrial impairment59,264,266,267

or brain inflammation (sometimes itself a result of oxidative stress, amenable to reduction with

melatonin225,437

), since associated with greater production of free radicals and an expected less favorable balance of oxidative stress to antioxidant

defenses, may be a risk factor for problems with the added oxidative stress from RF/MW, or from the depression in antioxidant defenses to which

RF/MW may contribute.

RF/MW may

depress

xenobiotic

protections

RF/MW has been reported to depress butyrylcholinesterase438

, an important xenobiotic defense enzyme. Depressed activity of this enzyme is tied to

higher cardiovascular and all-cause mortality439

.

Oxidative

Stress

contributes to

Auxiliary

Mechanisms

of radiation

injury, such

as

Mitochondrial

Dysfunction.

Oxidative stress contributes to multiple documented auxiliary mechanisms of RF/MW damage that likely contribute to health effects in subsets,

including membrane alterations (cell membranes440

and mitochondrial membranes441-444

), blood brain barrier disruption166,168-170,172,173,445-449

, effects on

voltage gated calcium channels450

(affected by and affecting oxidative stress451,452

), but also on voltage gated anion channels that are an important part of

the outer mitochondrial membrane453

– potentially contributing to mitochondrial impairment and amplification of oxidative stress, EEG spiking233

,

impaired mitochondrial function240,454

(bidirectionally related to oxidative stress58,455,456

– and protected by melatonin457

), impaired blood flow (e.g. via

oxidative stress driven endothelial dysfunction)458-461

, autoantibodies249,255,462-466

, and apoptosis467-476

(programmed cell death – which in turn triggers

inflammation and coagulation activation477

). Laboratory correlates for some of these were reported in ES participants in the French study: ~15% of those

with ES had elevated markers of blood-brain barrier permeability; 29% in those with ES (23% in those with ES and multiple chemical sensitivity

(MCS)) had antibodies to O-myelin33

.

Melatonin

considerations

:

RF/MW/EMR

vs diplomats

While depressions in a melatonin metabolite were the norm in participants with ES in a French study33

, this need not necessarily be the case for

diplomats, even if a related cause (pulsed RF/MW) and related processes (e.g. tied to oxidative stress) are involved in symptom induction. In persons

with “ES,” lowered defenses are needed, for nominally “modest” exposures to produce problems. But if exposures in affected diplomats were more

intense or otherwise injurious, lowered defenses would not be required to produce injury. To assess this, it may be prudent to assess urine melatonin

metabolites at the time diplomats are identified with symptoms.

Psychogenic

illness has

been

dismissed

Psychogenic causation has been repeatedly suggested as the basis for diplomats’ symptoms13,14,478

.

This has been correctly dismissed, however, for the Cuba and China diplomats11,40,41

.

Psychogenic causation has similarly been suggested for symptoms from RF/MW479

and has been similarly repudiated108,480

. The Swiss Telecom funded

study that documented a relation of sleep problems to transmitter field strength, also showed that symptoms were not related to a health-worrying

personality48,68

. The concordance of symptom profiles across studies, the emergence of RF/MW problems in people unaware of the exposure or its

potential for problems, the concordance of symptoms and objective signs with known documented mechanisms of RF/MW injury, the presence of

objective markers and ties to genetics that each cohere with known mechanisms of RF/MW injury33,67,116

effectively preclude a psychogenic basis for the

problem – were such a diagnosis meaningful.

{See below, in the entry for study inconsistency, for provocation studies.}

The notion that chronic symptoms can arise from psychogenic sources dates to Freud, who also pioneered the flaws associated with its application481

.

The foundation is substantially circular, a mechanism has never been physiologically defined or substantiated (much less documented to be operating in

cases where the label is applied), and the label is deployed without the most basic scrutiny of the tacit assumptions482

. Historically, many conditions that

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were presumed psychogenic (such as ulcers, seizures) were recognized as organic as evidence emerged482

.

Not all are

affected – a

minority of

embassy

personnel R,

and of

RF/MW

exposed

How might some people experience symptoms and signs of injury from what seem to be “low levels” of an exposure, seemingly well below levels that

other people tolerate? For toxins we designate an “LD50”483-488

(dose lethal in 50%) – or an LD5. This reflects the recognition that for each potentially

toxic exposure, there is a range in which some will experience an outcome and others will not. One can also define an SD50 (symptoms in 50%) – or an

SD25, or SD5. It would be surprising if a highly useful and lucrative technology were not pushed as far into this intensity range as possible. Genetic

variations in a range of free radical detoxification systems, competition for those systems, alterations in gene expression based on prior exposures,

differences in vulnerability of the tissue affected (via factors like mitochondrial “heteroplasmy,” past injury of that organ), and variations in secondary

mechanisms triggered by oxidative stress, provide among the mechanisms by which variability is produced.

The de facto intensity of the “same” exposure may differ radically (no pun intended) from person to person †. A further mode of variability arises from

immune activation. Considering a more familiar “allergen,” one person can eat a jar of peanut butter without problem; while another is hospitalized for

exposure to a crumb of peanut. As above, oxidative stress can modify substances in a fashion that makes them vulnerable to autoimmune attack.

Immune/autoimmune activation is a documented feature in a subset of those citing symptoms from RF/MW/EMR33

.

Effect

modification

“Effect modification” refers to differences in effect in different individuals, and it is the rule rather than the exception in biology. Particular

considerations are germane when the exposure has potential for prooxidant or antioxidant effects489

. Many prooxidants can be antioxidant at low doses in

some people (via “oxidative preconditioning” in which low level exposure to prooxidants may upregulate native antioxidant defenses; this can lead to net

antioxidant effects in persons whose defenses are not already overwhelmed or maximally upregulated – as above). Conversely, many substances thought

of as antioxidants are prooxidant in some settings, often including high dose490-498

. So the same exposure can produce even opposite direction effects in

different persons. Exemplifying the principle, statin cholesterol-lowering drugs are net antioxidant in many people (often tested in nonelderly males

without metabolic syndrome factors), but are reproducibly prooxidant in a subset – and prooxidant dominance is tied to side effects499,500

. These side

effects (attended by net prooxidant effect499,500

) arise disproportionately with higher doses, and in persons with conditions like older age and metabolic

syndrome factors, that are statistically tied to mitochondrial impairment56

. Side effects, too, occur disproportionately in women56

. Women show higher

rates of adverse effects from many drugs and environmental toxins (and many medical procedures); they are also more often affected by EMR91,102,259,424,

501.

There are many potential sources of effect modification from genetics (as has been documented67

), level of exposure, and past and current environment

that influence biology. Some exposures may cause mitochondrial injury or oxidative stress (competing for antioxidant defenses) or depress

concentrations of antioxidants, boosting vulnerability. Other exposures may have protective effects.

Chemical

exposures

may serve as

one source of

effect

modification

Many drugs and chemical exposures cause oxidative stress, cause mitochondrial injury (which also increases intracellular oxidative stress), depress

antioxidant defenses, and/ or compete for or inhibit detoxification systems. Through these and other mechanisms, these exposures may magnify harm

from RF/MW and vice versa. Preliminary evidence comparing chemical levels in Swedish persons with ES vs controls identifies higher levels of some

organic pollutants in those with ES26

– though larger studies are needed.

Melatonin and glutathione (and other antioxidants) can be “radioprotective”204,307,502,503

(here the root “radio” refers to radiation, not specifically to

radiofrequency radiation). Other agents or conditions can be “radiosensitizing.”

As might be expected, glutathione depletion can be radiosensitizing, though the status of other antioxidants may be important504-507

. The tie between low

melatonin (assessed by the principle metabolite) and ES in the French study33

supports the expectation that melatonin depletion is radiosensitizing as

well. Radiosensitization is used therapeutically, to enhance killing by radiation of tumor cells508

, but its existence there is a reminder that chemicals

interact with radiation to modify radiation effects. Radiation itself may be radiosensitizing – as potential effects on antioxidant systems, reviewed

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elsewhere, suggest – and reportedly ultra high frequency radiation is a particularly effective radiosensitizer509

. Oxidative stress is an important, but not

the only, means by which radiosensitization occurs510

, consistent with multiple downstream mechanisms of injury.

(Of note, because critical systems that are involved in radiation defense – like melatonin, glutathione, and other antioxidant systems – are also involved

in defense against toxicity of chemicals and drugs511

, and because factors that adversely affect antioxidant:oxidant balance may be adverse for oxidative

stress mediated injury from either type of source, it is expected – as it is observed – that there will be overlap between chemical and electrical

sensitivity33

.)

Two illustrations where we can see the radiosensitizing effect occur with ultraviolet (uv) light, since due to its high frequency, the effect is primarily on

the skin. Photosensitizing agents and “radiation recall” are the illustrations.

Photosensitizing or phototoxic or photoallergic agents are agents that magnify damage observed with uv radiation. (For simplicity we will use

“photosensitizing” to encompass each of these.) In some cases, radiation breaks down a chemical to something toxic. Drugs may also photosensitize, for

instance, by augmenting one of the mechanisms of radiation injury, such as oxidative stress or mitochondrial dysfunction512

. Fluoroquinolone antibiotics,

which can cause serious problems in a vulnerable subset through oxidative stress and mitochondrial dysfunction55

, are strongly reported to photosensitize

and to be phototoxic513-531

. Fluoroquinolones have been tied to development of persistent phototoxicity (following withdrawal of the drug)532

– i.e.

ongoing higher vulnerability to this radiation – consistent with evidence that a vulnerable group experiences persistent damage from fluoroquinolones in

which oxidative stress and mitochondrial injury play a role55

. This “vulnerability” may be acquired, as mitochondrial injury can be cumulative, and a

serious reaction sometimes follows a previous course of fluoroquinolones with a milder and time-limited reaction or none at all55

. (Mitochondrial injury

from radiation can also be cumulative533

.) Fluoroquinolones have led to reported “photosensitivity” reactions to fluorescent lighting534

. Statins, which as

elsewhere are sometimes prooxidant499

and sometimes mitochondrially toxic56

, are also sometimes linked to photosensitivity535,536

. (The below

information about photosensitivity in Smith Lemli Opitz explains one reason that statins can be prooxidant, though they also have antioxidant

mechanisms.)

Given oxidative mechanisms of radiation injury that apply across the electromagnetic spectrum, it is expected that some agents that photosensitize may

sensitize to other forms of radiation – potentially including RF/MW. Others have noted that photosensitizing drugs have played an apparent role in other

radiation injury537

. (Data we have presented, but not published, showed that past use of fluoroquinolones was significantly tied to development of ES;

past adverse effects to fluoroquinolones, which signify oxidative-mitochondrial injury to a point producing symptoms (at least, they surpassed the

symptom threshold for a time), showed a particularly strong connection52

.)

There are also disease conditions tied to magnified photosensitivity538

. Where these are tied to depressed antioxidant defenses, or increased

mitochondrial injury, they might be predicted to be tied to increased risk of ES development (accounting for radiation exposure). In Smith Lemli Opitz

syndrome, which many studies have tied to photosensitivity, cholesterol levels are low539-550

. Cholesterol transports critical fat soluble antioxidants56

.

In the phenomenon of “radiation recall,” injury to tissue initially caused by radiation can be made to reappear by another agent with shared mechanisms

of injury, e.g. oxidative stress and mitochondrial injury – such as fluoroquinolone antibiotics – best recognized for skin reactions, since we are able to see

these551-553

.

Are

provocation

studies

contributory?

Several so-called provocation studies have been conducted in persons with ES; some focus on symptoms, some on objective markers. In most of those

that focus on symptoms, those with ES fail to reliably distinguish between blinded EMR “exposed” and “unexposed” settings554

. Major flaws in the

designs have been recognized and reviewed by others96, 102

: for instance, studies assume that the details of exposure and time course do not need to be

individualized, which is contrary to the evidence.

But there are further problems. The most fundamental is the assumption that in ES, symptoms serve as a meter; this is invalid. Consider the analogy of

sunburn – a form of radiation injury mediated by oxidative stress, that affects some but not others at usual exposure levels. Those who are affected

“believe” sun exposure is responsible. They would be unlikely to discern when they are being exposed vs not to ultraviolet radiation. (It is their failure to

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know when significant injury is occurring, or has occurred that leaves them in the sun long enough to receive injury.) What is discerned is the

inflammation (that follows the oxidative stress) that may only emerge late in exposure, or after the sun exposure has been “withdrawn.” A blinded sham-

exposed study would likely also produce inability to discern sham from active treatment.

People do not sense the EMR, but the effects produced by it, and studies show that those with ES respond to different EMR sources. In RF/MW-affected

persons, as in diplomats, the effects can arise after hours of exposure, or hours after a short exposure – oxidative stress can cause apoptosis and can then

trigger inflammation477

, or can cause blood brain barrier damage allowing brain swelling (see above) – progression of these mechanisms may not peak

for hours or in some cases, even a couple of days. Recovery from effects can take still longer.

For such a study to have a chance to succeed, it would be essential to pretest and individualize both the control/negative exposure condition, and the

active/positive exposure condition (including exposure and time course) in each individual, to define a condition that will be effective in that person – if

such conditions can be successfully defined, and if cumulative effects don’t alter the condition from one trial to the next. For some people the

background EMR at the facility, or its parking lot or lobby; or the exposure during transit to the facility may obviate ability to define a negative exposure

condition for that individual. It would be better to bring the EMR exposure to a place where the affected party is stable and asymptomatic. And the

specific EMR and timing must be individualized to produce a positive condition, in a suitable time course.

To be valid, such a study must also protect against the possibility of physiological conditioning effects. These are distinct from “nocebo” effects, and

arise because the true stimulus produces actual physiological harm: It is known, for instance, that chemotherapy patients may vomit when they enter the

room in which they have received chemotherapy. (Chemotherapy agents, like EMR, also cause toxicity via oxidative stress344, 555-557

and mitochondrial

injury558

.) The fact that symptoms occur also with expectation of chemotherapy does not mean that the chemotherapy itself lacks toxicity (or that

perceived adverse effects are due to a “nocebo” effect); rather, expectation produces symptoms because the exposure is toxic. Expectation of the noxious

exposure may, via conditioning processes, produce symptoms ordinarily produced by the noxious exposure. (This is potentially evolutionarily adaptive –

serving to encourage persons to avoid settings in which the toxic exposure is expected.) To ensure against conditioned effects arising with expectation, a

set of negative exposure visits at the test site before (and between) each positive exposure visit may be required to ensure “extinction” of physiologically

conditioned expectation effects. In essence, the setting that optimizes prospects to identify a real effect, if present, is that in which the participant believes

there will not be an active exposure.

N-of-1 studies that focus on physiological effects of EMR have proven somewhat more able to identify EMR effects in those with ES, or subsets of them

for which that physiological marker is affected. Just as symptoms vary, so physiological changes do so, so outcomes suited to one person may not apply

for all. Physiological markers changed with blinded EMR exposure in a published study of a female physician with ES. She could not discern when the

exposure was present or not, but measurable changes occurred and symptoms arose with the positive condition27

. Symptoms were significantly more

intense with pulsed (but not continuous) radiation than sham exposure27

. An N-of-1 test was reportedly conducted in a former Miami organized crime

prosecutor, who developed ES and chemical intolerance, with seizures an important part of his clinical profile, following a significant chemical

exposure. An EEG was undertaken, turning on and off a TV, with the party blinded to the stimulus (blindfolded and with headphones to prevent him

hearing when the TV was turned on or off). When the TV was shielded, no effect on the EEG was seen. With an unshielded television, EEG changes

including seizure activity occurred when the television was turned on (and he experienced physical twitching)559

. {This particular marker is unlikely to

be generally useful, as seizure activity is not a usual part of the clinical profile in those affected by RF/MW.} A provocation study focused in a group of

individuals showed changes in heart rate variability116

, an index of autonomic function that is tied to hard outcomes like sudden death and coronary

artery disease560,561

. Moreover, three of the four participants who characterized their ES as “intense” (though only persons in this group) exhibited

striking heart rate increase of between 45 and 90 beats per minute virtually immediately with the microwave exposure, associated with marked increase

in sympathetic response. Declines in parasympathetic response with RF/MW exposure were seen for 23 of 25 tested people, in all groups (including,

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though less so, those with no ES).

In general, assessments of objectively measurable quantities of relevance, including both differences in affected vs unaffected persons irrespective of

current exposure33,67

, and changes occurring with exposure116

, provide a more promising approach than real-time assessments of subjective outcomes for

understanding this condition.

Financial

conflict of

interest is a

major source

of apparent

disparities in

results

One key source of disparities in study results is financial conflicts of interest. When present, financial conflicts strongly predict that study results will

conform to the financial interests of authors or funders98,99,562-566

. An analysis examined why some review articles on passive smoking concluded it was

harmful while others concluded it was not: The only identified factor that predicted which conclusion, was industry conflict by authors – which was often

undisclosed566

. Richard Smith, the former Editor in Chief of the BMJ (the British Medical journal) observed that this suggested that “far from conflict of

interest being unimportant in the objective and pure world of science where method and the quality of data is everything, it is the main factor

determining the result of studies”99

.

Financial conflicts have been a concern specifically in relation to RF/MW, both for studies and for regulatory decisions93-96,567

. In an analysis of studies

looking at cell phone effects as a function of funding source, “Studies funded exclusively by industry reported the largest number of outcomes, but were

least likely to report a statistically significant result” {So, they report everything that wasn’t affected?} “The odds ratio was 0.11 (95% confidence

interval, 0.02–0.78), compared with studies funded by public agencies or charities. Analogous to findings for a relation of industry funding to failure to

find tobacco related problems566

, the finding was not materially altered in analyses adjusted for the number of outcomes reported, study quality, and

other factors”93

.

It has been generally assumed that the disproportionately product-favorable results from industry-funded studies (including less evidence of product

harm) arises by virtue of choices, selecting study design, exposure specifics, subjects, and outcomes to support the desired result. (See below, these can

in fact influence outcomes.) But where harms of lucrative products are concerned, there is precedent for industry-funded studies going beyond those

factors to hide even large and lethal harms, even for prespecified or primary outcomes – via means that have the appearance, at least, of fraud568,569

.

Special circumstances enabled the apparent shenanigans in those cases to be uncovered. Whether frank manipulation of data to hide harms of lucrative

products is the rule or the exception in industry-funded studies is simply not known.

Because of a robust body of evidence documents a strong relation of industry conflicts to outcomes, deliberations and standards should be based

exclusively on studies in which such conflicts of interest are absent. (Industry funded-studies can be used for hypothesis generation.) This obviates one

major source of apparent inconsistency in studies. But it eliminates inconsistencies due to this factor, only as far as it is possible to discern when

financial conflicts are operating.

Study

outcomes may

appear

different

without

“inconsistency

”: Details

matter, to see

an effect

Design features can influence outcomes, and may be selected to do so.

Details of RF/MW exposure that may influence outcomes include the following (some relevant features have doubtless been missed):

- Radiation frequency or frequencies570-572

- Radiation intensity78

- Radiation waveform78

- Polarization571,573,574

- Pulsed vs continuous radiation574,575

- Pulse width100

- Time between pulses187

/ repetition rate47

- Pulse waveform47,576

- Pulse intensity45

- Exposure duration577,578

, and

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- Exposure intermittency579

- on every time scale

- Environmental conditions – temperature, humidity, air currents78,580

- Concurrent (or preceding) exposures to other radiation78,97,581

– which can cause synergistic effects78

- Concurrent (or preceding) chemical exposures or environment97,581

- State of health of the animal or subject78

- Species78

- Size of the subject relative to wavelength78

- Genetics of the animal67,571

- Antioxidant/ nutrient status of the animal or subject234,235,304,305,434,582-588

- Orientation of the animal or subject relative to the radiation source78

- Portion of the body irradiated78

- Time between exposure and assessment of effect571

- Effect measured

- Metric used to measure effect

Radiation that is pulsed, that is polarized, that is applied intermittently, that is more intense, and that is applied for a longer time, may be more likely to

produce problems, for instance.

Even for studies nominally examining the “same” RF/MW exposure, different choices may be made. A range of choices are illustrated in this text:

“There are 124 different channels/frequencies that are used in GSM900 mobile communication. They differ by 0.2 MHz in the frequency range between

890 and 915 MHz. The test mobile phone was programmed to use channel 124 with the frequency of 915 MHz. The signal included all standard GSM

modulations. No voice modulation was applied. A GSM signal is produced as 577 ms pulses (time slots), with an interpulse waiting time of 4039 ms

(seven time slots). The test phone was programmed to regulate output power in the pulses in the range of 0.02–2 W (13– 33 dBm). This power was kept

constant during exposure at 33 dBm, as monitored online using a power meter (Bird 43, USA)”187

.

Studies that examine symptoms as a function of distance from cell tower base stations suggest that in important, real world settings, more intense

RF/MW exposure is generally a greater problem68,151,259,589

) – though there may be an intensity range below which this ceases to be the case.

In some conditions, nonmonotonic effects of radiation have been reported574,590

, and they are arguably expected for agents in the antioxidant-prooxidant

spectrum (high dose antioxidants are often prooxidant, low dose prooxidants, via oxidative preconditioning, may be antioxidant). Opposite direction

effects on a critical mechanism can produce opposite direction effects in a resulting outcome. Thus, lower doses of vitamin E fluidize, and higher

concentrations stabilize membranes591

; low vitamin E benefits and higher vitamin E harms vasodilatory function in cholesterol-fed rabbits592

; “Low

tocopherol concentrations have stronger antiinflammatory effects in PUVA-induced erythema than higher concentrations”593

; low doses are tied to lower

mortality in people, higher doses to higher all-cause mortality594

, etc. For statins, an agent class that can produce prooxidant or antioxidant effects,

bidirectional effects have been shown on many outcomes595

– female sex and features tied to greater likelihood of mitochondrial problems are risk

factors for harms – as is higher dose or use of a higher potency agent56

. It is common that where a lower amount of something may be favorable (or

neutral), a higher amount may be adverse – with a transition zone in which subject characteristics and covariables matter a lot in determining the

direction. (There are instances in which this directionality is flipped596

– for instance, sometimes a sufficient concentration leads an adaptive protection to

be triggered.)

Beyond characteristics of the radiation, the subject may be exposed to it differently – e.g. in animal studies, there may be whole body radiation597

or

head-only exposure181,598

, triggering a different spectrum of responses – and with in vitro exposure, even fewer of the variables that might contribute to

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effects are present. The environment in which exposure occurs may differ in ways that influence toxicity of radiation, for instance differences in

temperature may produce different effects580

, or concurrent or background electromagnetic exposure581

or chemical exposures97,599

. Amphetamine use

represents one exposure that has been reported to magnify problems with RF/MW47

.

Characteristics of the “subjects” may differ. In animal and in vitro studies, they may differ in species, strain, genetic features, cell type, cell preparation,

and cell density571,599

, for instance.

“Effect modification” refers to the phenomenon by which effects, including adverse effects, are not equal in all subgroups. This is a major issue

throughout biology, and particularly for exposures mediated by oxidative stress and cell energy impairment. Findings with statin cholesterol lowering

drugs illustrate how massive the disparity may be as a function of participant group. Like RF/MW, these agents have potential for toxicity through

prooxidant and mitochondrial adverse mechanisms56,499

. RF/MW disproportionately affects sleep and hearing (through its special extra features) – but

muscle and tendon problems are sometimes reported48,102,108

. Fluoroquinolones disproportionately affect tendons through their extra mechanisms (statins

can do so too, though more rarely600-603

). Statins disproportionately affect muscle – the most feared muscle complication is rhabdomyolysis, massive

breakdown of muscle that can overwhelm the kidneys and lead to kidney failure and death (which is also reported with fluoroquinolones though more

rarely604-612

).

Statins were commonly hailed as so safe they should be put in the water supply613-616

. But analysis of insurance claims data show that (focusing on the

one adverse effect) while the rate of rhabdomyolysis was rare overall, it was frankly common in identifiable vulnerable subgroups. Hospitalized

rhabdomyolysis, per year of treatment, occurred in fewer than 1 in 22,000 on statin monotherapy. However, the rate was far higher for older diabetics

also on a fibrate (a second class of cholesterol lowering drug), and if they were on the statin agent whose clearance was most affected by fibrates,

rhabdomyolysis occurred in about 1 in 10 per year of treatment617

. So, depending on characteristics of the exposure, co-exposures and the subject, rates

of a problem – and ability for science to show the problem – can vary widely. (The particular statin agent that caused the worst problems was pulled

from the market, but the conceptual point stands.) Risks of harm with exposures are not distributed equally. A problem that appears very rare overall, or

in one test group – often apparently not increased relative to unexposed – can be frankly common in another. If the groups most at risk are not studied, or

their presence is seriously diluted, serious harms can be missed. Studies that fail to detect a harm do not invalidate those that show one – and are not of

equal importance where a purpose is to establish that harms can occur.

Rates of

problems

Though a minority of embassy personnel were reportedly affected11

, it is unclear how many were exposed. The fraction of US diplomats in Cuba (and

now China) reporting effects may be higher than the fraction of civilians citing similar severity problems with RF/MW exposure – though in neither

group can the exposure of those affected be presumed to have been typical. Table 3 suggests that once persons are symptomatic, the profile of symptoms

is similar. The reportedly high prevalence of Frey-compatible effects, and what seem a comparatively large number of diplomats in Cuba affected,

suggest exposures of a more intense or more damaging character – considering intensity, frequency, pulse waveform, pulse duration, duration,

polarization, interconcurrent exposures, and many other factors influence injury from RF/MW571

.

Natural

History

Both diplomats9 and RF/MW affected individuals

49,102 have shown variable time course to onset of symptoms after apparent inciting exposure; and

variable time course and completeness of recovery with time away from the exposure. Doctors submitting the Bamberg Appeal to the Prime Minister of

Germany noted: “The symptoms occur in temporal and spatial relationship to exposure…Some of the health disturbance disappears immediately the

exposure ceases (removal of DECT telephone, temporary moving away from home, permanently moving away, using shielding)”109

. An “intervention

study” from Japan, involving the “intervention” of removing a cellular phone base station on a condominium, affirms improvement with removal of the

exposure. 107 of 122 inhabitants were interviewed and had medical examinations at two time points, while the base station was in operation, and three

months after it was removed. “The health of these inhabitants was shown to improve after the removal of the antennas, and the researchers could identify

no other factors that could explain this health improvement…The results of these examinations and interviews indicate a connection between adverse

health effects and electromagnetic radiation from mobile phone base stations“618

.

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36

Natural history could differ for diplomats, who may have been exposed to a more intense stimulus or one with more injurious characteristics – suggested

by what appear to be a comparatively high number affected, and high prevalence of Frey effects. With a powerful exposure, depressed defenses are not

equally required to produce injury. There is not a basis to know if affected diplomats will have heightened vulnerability to “usual” RF/MW exposures

going forward – though this bears assessing.

† An illustration from a common drug, and a common food: “Grapefruit juice increased the mean peak serum concentration (Cmax) of unchanged simvastatin about 9-fold

(range, 5.1-fold to 31.4-fold; P < .01) and the mean area under the serum simvastatin concentration-time curve {AUC (0-infinity)} 16-fold (range, 9.0-fold to 37.7-fold; P

< .05)”619

. Thus, just one comparatively innocuous interacting factor – grapefruit juice (which inhibits an enzyme involved in simvastatin metabolism) – led some to have a

38-fold greater blood “amount” of a drug, than that same person would have had without the juice. Potential differences are magnified comparing different persons

with/out juice; and moreso factoring in impact of other exposures. Other risk multiplying factors are tied to the individual: The same serum level can produce a radically

different impact from person to person: relevant factors include genetic differences in muscle, and factors that reduce energy supply, or that increase energy demand to

muscle56, 620-624

. Thus, what is the “same” exposure before it hits two people, can become a radically different exposure once it interacts with individuals’ biology.

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Table 5. RF/MW Source Considerations.

What kinds of

RF/MW

sources affect

civilians?

In the UCSD survey, smart meters were the dominant inciting trigger (~50% of those ~70% who recognized a triggering episode), with cell phones, Wi-

Fi introduction or new routers, medical radiation and other factors also reported52

. The range of apparent triggers has been vast, with RF/MW and

particularly pulsed RF/MW commonly implicated. Considering those who have communicated with us, a couple from Scotland became affected several

decades ago, after they moved to a rural area, but across from a radar factory. Though they moved away, both remain “electrosensitive” decades later.

Others became affected when a cell tower was placed next to their home. Dr. Gro Harlem Brundtland reports becoming sensitized following exposure to

a malfunctioning microwave oven (in an episode that also reportedly blinded her for a year)32,625

. An Australian veteran reports that he became affected

during his military service, working with radiofrequency radiation (radar workers in the military were among the first groups in whom such problems

were recognized, many decades ago). One who communicated with us became sensitized in association with their job placing radio collars on wildlife.

An architect who contacted us was sensitized after several months working closely with Bluetooth-enabled lighting devices. Parents reported to us the

onset of ES in their children with Wi-Fi introduced to the school, accommodations were denied, forcing parents to remove their children from school and

move elsewhere, and forcing some teachers from their job241,626

. In Sweden and the UK, a controversial radio system called TETRA reportedly caused

health problems in some police officers: severe insomnia in a Swedish officer resolved when the officer’s managers noted the connection, and placed the

officer in a room without the exposure625

. Some US firefighters were affected after municipalities placed cell towers on roofs of fire stations627

:

“Symptoms experienced by the firefighters have included neurological impairment including severe headache, confusion, inability to focus, lethargy,

inability to sleep, and inability to wake up for 911 emergency calls. Firefighters have reported getting lost on 911 calls in the same community they grew

up in, and one veteran medic forgot where he was in the midst of basic CPR on a cardiac victim and couldn’t recall how to start the procedure over again.

Prior to the installation of the tower on his station, this medic had reportedly not made a single mistake in 20 years.”628

. The International Association of

Fire Fighters Division of Occupational Health, Safety and Medicine crafted a position paper627

, and firefighters were exempted in the recent proposed

California bill, SB-649628, 629

, that sought to bypass local control in placing of 5G cell towers628

.)

These were not “nocebo” effects: many developed symptoms prior to identifying the source of the problem (or in some cases even being aware that the

exposure existed at that time). Many had no idea the exposure had potential to produce problems. They were blindsided by onset of new problems. The

causes were identified by their spatial and temporal relationship to onset, worsening and abatement.

Reports of problems from commercial sources of RF/MW have emerged from many nations including (e.g.) Russia67,80

, Korea630

, Japan50

, Taiwan631

,

Turkey261

, Israel632

, Australia48

, New Zealand30

, France33

, England314,633

, Ireland314,634,635

, Spain24,151,636

, Italy67,314

, the Netherlands102

, Switzerland68,92

,

Austria25,90,314,637

, Germany314,638

, Denmark314,639

, Sweden36,424

(where Ericsson designer Per Segerbäck was seriously affected640

), Norway641

(afflicting

3-time Prime Minister Gro Harlem Brundtland, as above), Finland29

(reportedly affecting former Nokia Chief Technology Officer Matti Niemela642

), the

US32,34,38,91

, where affected former Silicon Valley techies Peter Sullivan643

and Jeromy Johnson644

strive to bring attention to the problem; and Canada

(where Frank Clegg, formerly head of Microsoft Canada, now of Canadians for Safe Technology – spearheads the effort toward recognition645

).

Past RF/MW

use and

Diplomats

Exposure of diplomats to RF/MW is not a new phenomenon. The US embassy in Moscow was reportedly radiated with microwaves from 1953-1988

(other sources give earlier or later end dates), spawning efforts by the US to shield the embassy75,76

. The Soviets claimed the purpose was to jam US

listening devices75

.

Based on reports of past embassy staff, a number of personnel and their offspring developed health effects, some developed white blood cell count

elevations, and a couple developed hematological malignancies76

. Elevated white blood cell counts108

(as well as depressed ones78

) have elsewhere been

reported in association with RF/MW, as have hematological malignancies646,647

, including a recent report of an occupational relationship of RF/MW to

“hemolymphatic” malignancies in the military setting: “The PF {percentage frequency} of HL {hemolymphatic} cancers in the case series was very

high, at 40% with only 23% expected for the series age and gender profile, confidence interval CI95%: 26-56%, p<0.01, 19 out of 47 patients had HL

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38

cancers. We also found high PF for multiple primaries. As for the three other cohort studies: In the Polish military sector, the PF of HL cancers was 36%

in the exposed population as compared to 12% in the unexposed population, p<0.001. In a small group of employees exposed to RF/MW in Israeli

defense industry, the PF of HL cancers was 60% versus 17% expected for the group age and gender profile, p<0.05. In Belgian radar battalions the HL

PF was 8.3% versus 1.4% in the control battalions as shown in a causes of deaths study and HL cancer mortality rate ratio was 7.2 and statistically

significant. Similar findings were reported on radio amateurs and Korean war technicians. Elevated risk ratios were previously reported in most of the

above studies”648

. (There was a news report of a “blood disorder” in a Cuban diplomat, but its character was unspecified15

.)

A controversial Johns Hopkins study was commissioned to assess the health of Moscow embassy personnel, but was never published in peer reviewed

literature. Staff from other Eastern European embassies were used as controls649

– a problematic control group as these are the embassies most likely to

have been subjected to similar exposures; indeed a FOIA request reportedly yielded claims of exposure from employees at other embassies649

. A

reanalysis asserted that Russian and Eastern European diplomats if combined, exhibited a significant increase, relative to expectation from the general

US population, in three cancer types649,650

that have each been associated with RF/MW exposure in other studies – hematological malignancy648

, brain

cancer651-654

, and breast cancer655,656

. Some complaints, such as vision problems, concentration problems, memory loss, depression and “other symptoms”

were greater in the Moscow than the comparator group, in either men or women or, for vision and concentration problems, in each men and women.

Given a presumed vulnerable subgroup, a problematic study design, and absence of a quality report, it is difficult to draw meaningful inferences –

beyond that some diplomats were exposed, and some who were exposed reported health problems.

Current

RF/MW

Source

Possibilities in

Diplomats

The source of proposed EMR/RF/MW (probably pulsed) affecting diplomats is not a principal focus of this paper.

For the diplomats in Cuba, causative RF/MW could in principle emanate from monitoring/surveillance devices (as has been speculated for microwaving

of the US embassy in Moscow75

); from efforts to jam our listening devices, as claimed by the Soviets75

; from electronic weaponry, or conceivably from

“innocent” communications sources of the type that affect some civilians (but presumably of higher typical intensity, or shorter pulse duration, or in the

setting of other exposures that amplify oxidative stress, or with some other feature that amplifies the fraction affected).

Surveillance-related efforts would seem perhaps the most likely, given the apparent preferential involvement of diplomats, in Cuba and China.

Room sweep

by FBI yielded

no devices10

The source of the historical microwave exposure on the US embassy in Moscow was also outside the embassy building. It reportedly originated from the

building next door, and later from the building across the street75

.

Smart meters (or banks of them) – outside the room – were the number one reported instigating cause of symptoms in the UCSD survey, with other

causes including base stations or cell towers outside the home. Pulsed RF/MW producing devices thus need not be in the room. The exposure can be

short term or intermittent – it need not be continuous. For this reason, devices in whatever their location need not remain present, after health effects

have been produced.

Acknowledgments: For kindly helping to retrieve articles for this, I thank Emily Nguyen, Hayley Koslik, Leeann Bui, Andrea Sember, Annabelle

Amos, Karl Chen, Arthur Pavlovsky, and Aubrey Bunday. I thank Hayley Koslik for assistance with the submission process.

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652. Hardell L, Carlberg M, Soderqvist F, Mild KH. Pooled analysis of case-control studies on acoustic neuroma

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653. Hardell L, Carlberg M. Using the Hill viewpoints from 1965 for evaluating strengths of evidence of the risk for brain

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http://wwwaracat/es/Hipersensibilidad-electromagnetica-trastorno-desconocido-alza_0_1688231329html?utm_medium=social@utm_source=facebook&utm_campaign=ara

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EUROPAEM EMF Guideline 2016 for the prevention, diagnosis and treatment

of EMF-related health problems and illnesses (2016)

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Rev Environ Health 2016; 31(3): 363–397

European Academy for Environmental Medicine (EUROPAEM) – EMF working group:*Corresponding author: Gerd Oberfeld, Department of Public Health, Government of Land Salzburg, Austria, E-mail: [email protected] Belyaev: Cancer Research Institute BMC, Slovak Academy of Science, Bratislava, Slovak Republic; and Prokhorov General Physics Institute, Russian Academy of Science, Moscow, RussiaAmy Dean: American Academy of Environmental Medicine, Wichita, KS, USAHorst Eger: Association of Statutory Health Insurance Physicians of Bavaria, Medical Quality Circle “Electromagnetic Fields in Medicine – Diagnostic, Therapy, Environment”, no. 65143, Naila, GermanyGerhard Hubmann: Center for Holistic Medicine “MEDICUS”, Vienna, Austria; and Wiener Internationale Akademie für Ganzheitsmedizin (GAMED), Vienna, AustriaReinhold Jandrisovits: Medical Association Burgenland, Environmental Medicine Department, Eisenstadt, AustriaMarkus Kern: Medical Quality Circle “Electromagnetic Fields in

Medicine – Diagnosis, Treatment and Environment”, Kempten, Germany; and Kompetenzinitiative zum Schutz von Mensch, Umwelt u. Demokratie e.V., Kempten, GermanyMichael Kundi and Hanns Moshammer: Institute of Environmental Health, Medical University Vienna, Vienna, AustriaPiero Lercher: Medical Association Vienna, Environmental Medicine Department, Vienna, AustriaKurt Müller: European Academy for Environmental Medicine, Kempten, GermanyPeter Ohnsorge: European Academy for Environmental Medicine, Wurzburg, GermanyPeter Pelzmann: Department of electronics and computer science engineering, HTL Danube City, Vienna, AustriaClaus Scheingraber: Working Group Electro-Biology (AEB), Munich, Germany and Association for Environmental- and Human-Toxicology (DGUHT), Wurzburg, GermanyRoby Thill: Association for Environmental Medicine (ALMEN), Beaufort, Luxembourg

Igor Belyaev, Amy Dean, Horst Eger, Gerhard Hubmann, Reinhold Jandrisovits, Markus Kern, Michael Kundi, Hanns Moshammer, Piero Lercher, Kurt Müller, Gerd Oberfeld*, Peter Ohnsorge, Peter Pelzmann, Claus Scheingraber and Roby Thill

EUROPAEM EMF Guideline 2016 for the prevention, diagnosis and treatment of EMF-related health problems and illnessesDOI 10.1515/reveh-2016-0011Received March 16, 2016; accepted May 29, 2016; previously published online July 25, 2016

Abstract: Chronic diseases and illnesses associated with nonspecific symptoms are on the rise. In addition to chronic stress in social and work environments, physi-cal and chemical exposures at home, at work, and during leisure activities are causal or contributing environmen-tal stressors that deserve attention by the general practi-tioner as well as by all other members of the health care community. It seems necessary now to take “new expo-sures” like electromagnetic fields (EMF) into account. Physicians are increasingly confronted with health prob-lems from unidentified causes. Studies, empirical obser-vations, and patient reports clearly indicate interactions between EMF exposure and health problems. Individual susceptibility and environmental factors are frequently neglected. New wireless technologies and applications have been introduced without any certainty about their health effects, raising new challenges for medicine and

society. For instance, the issue of so-called nonthermal effects and potential long-term effects of low-dose exposure were scarcely investigated prior to the introduc-tion of these technologies. Common electromagnetic field or EMF sources: Radio-frequency radiation (RF) (3 MHz to 300 GHz) is emitted from radio and TV broadcast anten-nas, Wi-Fi access points, routers, and clients (e.g. smart-phones, tablets), cordless and mobile phones including their base stations, and Bluetooth devices. Extremely low frequency electric (ELF EF) and magnetic fields (ELF MF) (3 Hz to 3 kHz) are emitted from electrical wiring, lamps, and appliances. Very low frequency electric (VLF EF) and magnetic fields (VLF MF) (3 kHz to 3 MHz) are emitted, due to harmonic voltage and current distortions, from electrical wiring, lamps (e.g. compact fluorescent lamps), and electronic devices. On the one hand, there is strong evidence that long-term exposure to certain EMFs is a risk factor for diseases such as certain cancers, Alzhei-mer’s disease, and male infertility. On the other hand, the emerging electromagnetic hypersensitivity (EHS) is more and more recognized by health authorities, disability

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364 Belyaev et al.: EUROPAEM EMF Guideline 2016

administrators and case workers, politicians, as well as courts of law. We recommend treating EHS clinically as part of the group of chronic multisystem illnesses (CMI), but still recognizing that the underlying cause remains the environment. In the beginning, EHS symptoms occur only occasionally, but over time they may increase in fre-quency and severity. Common EHS symptoms include headaches, concentration difficulties, sleep problems, depression, a lack of energy, fatigue, and flu-like symp-toms. A comprehensive medical history, which should include all symptoms and their occurrences in spatial and temporal terms and in the context of EMF exposures, is the key to making the diagnosis. The EMF exposure is usu-ally assessed by EMF measurements at home and at work. Certain types of EMF exposure can be assessed by asking about common EMF sources. It is very important to take the individual susceptibility into account. The primary method of treatment should mainly focus on the preven-tion or reduction of EMF exposure, that is, reducing or eliminating all sources of high EMF exposure at home and at the workplace. The reduction of EMF exposure should also be extended to public spaces such as schools, hos-pitals, public transport, and libraries to enable persons with EHS an unhindered use (accessibility measure). If a detrimental EMF exposure is reduced sufficiently, the body has a chance to recover and EHS symptoms will be reduced or even disappear. Many examples have shown that such measures can prove effective. To increase the effectiveness of the treatment, the broad range of other environmental factors that contribute to the total body burden should also be addressed. Anything that supports homeostasis will increase a person’s resilience against disease and thus against the adverse effects of EMF expo-sure. There is increasing evidence that EMF exposure has a major impact on the oxidative and nitrosative regula-tion capacity in affected individuals. This concept also may explain why the level of susceptibility to EMF can change and why the range of symptoms reported in the context of EMF exposures is so large. Based on our current understanding, a treatment approach that minimizes the adverse effects of peroxynitrite – as has been increasingly used in the treatment of multisystem illnesses – works best. This EMF Guideline gives an overview of the current knowledge regarding EMF-related health risks and pro-vides recommendations for the diagnosis, treatment and accessibility measures of EHS to improve and restore indi-vidual health outcomes as well as for the development of strategies for prevention.

Keywords: accessibility measures; Alzheimer’s disease; cancer; chronic multisystem illnesses (CMI); diagnosis;

electric; electromagnetic field (EMF); electromagnetic hypersensitivity (EHS); infertility; leukemia; magnetic; medical guideline; nitrosative stress; non-ionizing; oxidative stress; peroxynitrite; prevention; radiation; static; therapy; treatment.

Current state of the scientific and political debate about EMF-related health problems from a medical perspectiveIntroduction

The Environmental Burden of Disease Project assessed the influence of nine environmental stressors (benzene, dioxins including furans and dioxin-like PCBs, second-hand smoke, formaldehyde, lead, noise, ozone, particu-late matter and radon) on the health of the population of six countries (Belgium, Finland, France, Germany, Italy, and the Netherlands). Those nine environmental stressors caused 3%–7% of the annual burden of disease in the six European countries (1).

The Bundespsychotherapeutenkammer (BPtK) study in Germany showed that mental disorders had increased further and especially burnout as a reason of inability to work increased seven-fold from 2004 to 2011 (2). In Germany, 42% of early retirements in 2012 were caused by mental disorders, depression being the leading diagnosis (3). In Germany, psychotropic drugs are in third place for the prescriptions of all drugs (4).

The consumption of methylphenidate (Ritalin, Medikinet, Concerta), a psychotropic drug prescribed as a treatment for attention deficit hyperactivity disorder (ADHD) especially for young children and adolescents, has increased alarmingly since the early 1990s. Accord-ing to statistics of the German Federal Institute for Drugs and Medical Devices (Bundesinstitut für Arzneimittel und Medizinprodukte), prescriptions have increased even more dramatically since 2000 and reached a climax in 2012. In 2013, only a slight decline in the number of prescriptions was observed (5). Interestingly, the rapid increase in the use of methylphenidate coincides with the enormous expansion of mobile telecommunication and other related technologies, posing an open research question.

In Germany, work disability cases and absence days due to mental health disorders more than doubled from 1994 to 2011 (6). In the Organization for Economic Co-operation and Development (OECD) countries, a huge


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variability in the prescription of antidepressants has occurred and generally an increasing trend has been observed. Socioeconomic status and therapeutic stand-ards cannot fully explain these observations (7). Func-tional disturbances like chronic inflammation and changes of neurotransmitter functions caused by environ-mental influences have hardly been investigated.

A steady increase in the prevalence of allergic/asthmatic diseases globally has occurred, with about 30%–40% of the world population now being affected by one or more allergic/asthmatic conditions (8).

It is suspected that environmental conditions such as the increasing exposure of the population to electromag-netic fields (EMFs) play a causal role for EMF-related health effects (9–12), including exposure to radiofrequency radi-ation (RF), which emanates from, e.g. cordless phones (DECT), mobile phone base stations, and mobile phones (GSM, GPRS, UMTS, LTE), especially smartphones, data cards for laptop and notebook computers, wireless LAN (Wi-Fi), wireless and powerline communication-based smart meters, but also exposure to extremely low fre-quency (ELF) electric fields (EF) and magnetic fields (MF) including “dirty electricity”, which emanate from distur-bances on electric wiring, power lines, electric devices, and other equipment. For the society and the medical community, all of this raises new challenges.

While biophysical and biochemical mechanisms of biological effects of EMF at low-intensity levels are not exactly known, significant progress has been achieved in the last decades, and there are numerous data indicating that these mechanisms may overlap for ELF and RF effects (13–18). In the following sections, we provide some back-ground information on important aspects of EMF biologi-cal effects. However, this must not be misunderstood as a full review of the evidence. We do not always strictly dif-ferentiate between RF and ELF fields because of the above mentioned overlap in biological mechanisms. It should also be mentioned here that very specific exposure condi-tions may trigger biological responses in one individual, but not in others. Anecdotal reports, however, indicate that such individual responsiveness or susceptibility does expand over time and the intolerance then extends over a broad range of exposure conditions.

Chronic diseases and illnesses associated with unspe-cific symptoms are on the rise. In addition to chronic stress in social and work environments, physical and chemical exposures at home, at work, and during leisure activities are causal or contributing environmental stressors that deserve attention by the general practitioner as well as by all other members of the health care community. It seems certainly necessary now to take “new exposures” like EMF

into account, or as stated by Hedendahl et al. (19): “It is time to consider ELF EMF and RF EMF as environmental pollutants that need to be controlled”.

Worldwide statements of organizations regarding EMFThe recommendations of the World Health Organization (WHO) regarding ELF electric and magnetic fields and RF radiation, compiled by the International Commission on Non- Ionizing Radiation Protection (ICNIRP) (20, 21), are based on currents induced in the body (ELF) and thermal effects (RF).

Thermal effects are defined as effects that originate in elevated temperatures from the absorption of electromag-netic energy. The specific absorption rate (SAR) is defined as the rate of absorption of electromagnetic energy in a unit mass of biological tissue. It is proportional to the incre-mental temperature increase in that tissue. Indeed while a significant temperature increase must be avoided as it can be of immediate adverse health consequences (tissue necrosis, cardiac stress, etc.) exposures can be without (measureable) temperature increase either because of heat dissipation or because the exposure is too low to be associ-ated with relevant heating. The latter type of exposure is termed non-thermal. Biological and health-relevant effects at non-thermal levels have been shown and discussed by many research groups all over the world (9, 10, 22–24).

The ICNIRP recommendations were adopted by the EU in its Council Recommendation of 1999, without considering long-term non-thermal effects. However, it should be stressed that at an international EMF confer-ence in London (2008), Professor Paolo Vecchia, ICNIRP Chairman from 2004 to 2012, said about the exposure guidelines “What they are not”: “They are not mandatory prescriptions for safety”, “They are not the’ ‘last word’ on the issue”, and “They are not defensive walls for industry or others” (25).

For all RF-based non-thermal EMF effects, SAR esti-mates are not an appropriate exposure metric, but instead either the field intensity or power density (PD) in combi-nation with exposure duration should be used in safety standards (26, 14, 27). In contrast to the ICNIRP guidelines, the Russian safety standards, are based on non-thermal RF effects, which were obtained by several research insti-tutes in the former Soviet Union during decades of studies on chronic exposures to RF (28, 29).

In contrast to the WHO headquarter in Geneva, the International Agency for Research on Cancer (IARC), a WHO-affiliated specialized agency in Lyon, classified


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extremely low frequency magnetic fields (ELF MF) as pos-sibly carcinogenic to humans (Group 2B) in 2002 (30) and radio-frequency radiation in 2011 (24).

It should be noted that, during the last 20 years, more than 20 position papers and resolutions regarding EMF and health have been adopted by EMF researchers and physicians. These include the Vienna EMF Resolution, Austria, 1998; Stewart Report, UK, 2000; Salzburg Reso-lution, Austria, 2000; Freiburg Appeal, Germany, 2002; Catania Resolution, Italy, 2002; Irish Doctors’ Environ-mental Association Statement, Ireland, 2005; Helsinki Appeal, Finland, 2005; Benevento Resolution, Italy, 2006; Venice Resolution, Italy, 2008; Porto Alegre Resolution, Brazil, 2009; Russian National Committee on Non-Ioniz-ing Radiation Protection Resolution, Russia, 2001; Inter-national Doctors’ Appeal, Europe, 2012; and the Report of the Standing Committee on Health, Canada, 2015 (31–34).

In August 2007 and December 2012, the BioInitiative Working Group, an international group of 29 experts with different competences, published two groundbreaking reports “BioInitiative 2007/resp. 2012 – A Rationale for a Biologically-based Public Exposure Standard for Electro-magnetic Fields (ELF and RF)” edited by Cindy Sage and David O. Carpenter, calling for preventive measures against EMF exposure based on the available scientific evidence (9, 10). The BioInitiative reports are global milestones with respect to a comprehensive review of biological effects and health effects of low-intensity electromagnetic radiation as well as the conclusions and recommendations given for the public. The BioInitiative report 2012 includes sections on the evidence for effects on: gene and protein expres-sion, DNA, immune function, neurology and behavior, blood-brain barrier, brain tumors and acoustic neuromas, childhood leukemia, melatonin, Alzheimer’s disease, breast cancer, fertility and reproduction, fetal and neo-natal disorders, autism, disruption by the modulating signal, EMF medical therapeutics, as well as sections on: statement of the problem, the existing public exposure standards, evidence for inadequacy of the standards, the precautionary principle, global public health examples, key scientific evidence and public health recommenda-tions, and summary for the public and conclusions.

As it is mostly neglected as a health hazard, the Euro-pean Environment Agency compared the risks of non-ioniz-ing radiation (EMF) to other environmental hazards such as asbestos, benzene, and tobacco, urgently recommending to implement a precautionary approach regarding EMF (35). This position was confirmed and elaborated more compre-hensibly in further publications in 2011 and 2013 (36, 37).

In September 2008, a statement of the European Par-liament called for a review of the EMF limits set out in the

EU Council Recommendation of 1999, which was based on the ICNIRP guidelines, with reference to the BioInitiative Report (38). This was further strengthened in the Euro-pean Parliament resolution of April 2009 (39).

At the meeting in November 2009 in Seletun, Norway, a scientific panel adopted a Consensus Agreement that rec-ommends preventative and precautionary actions that are warranted now, given the existing evidence for potential global health risks from EMF exposure (40). Besides general and specific recommendations, e.g. for mobile and cordless phone use, the panel recommended exposure limits for ELF magnetic fields and radio-frequency radiation. It was stated by the panel: “Numeric limits recommended here do not yet take into account sensitive populations (EHS, immune-compromised, the fetus, developing children, the elderly, people on medications, etc.). Another safety margin is, thus, likely justified further below the numeric limits for EMF exposure recommended here”.

Since 2007 the Highest Health Council of the Ministry of Health in Austria has recommended to take preventive action by reducing exposure levels from RF devices which may lead to long-term human exposure of at least a factor of 100 below the guideline levels of the European Com-mission and by issuing rules on how to reduce one’s indi-vidual exposure to RF radiation from mobile phones (41).

In May 2011, the Parliamentary Assembly of the Council of Europe adopted the report “The Potential Dangers of Electromagnetic Fields and their Effects on the Environment” (42). The Assembly recommended many preventive measures for the member states of the Council of Europe with the aim to protect humans and the envi-ronment, especially from high-frequency electromagnetic fields such as: “Take all reasonable measures to reduce exposure to electromagnetic fields, especially to radiofre-quencies from mobile phones, and particularly the exposure of children and young people who seem to be most at risk from head tumors”, or “Pay particular attention to ‘electro-sensitive’ people who suffer from a syndrome of intolerance to electromagnetic fields and introduce special measures to protect them, including the creation of wave-free areas not covered by the wireless network”.

Recognizing that patients are being adversely affected by EMF exposure, the American Academy of Environ-mental Medicine (AAEM) published recommendations regarding EMF exposure in July 2012. The AAEM called for physicians to consider electromagnetic exposure in diagnosis and treatment and to recognize that EMF expo-sure “may be an underlying cause of the patient’s disease process” (43).

Since 2014, the Belgian government has prohibited the advertising of mobile phones for children under the age of


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7 and has required the specific absorption rate (SAR) of mobile phones be listed. Furthermore, at the point of sale, well-marked warnings must be posted that instruct users to use headsets and to minimize their exposure (44).

In January 2015, the French parliament adopted a comprehensive law that protects the general public from excessive exposure to electromagnetic waves. Among other things, it was passed to ban Wi-Fi in nurseries for children under the age of 3 and to enable Wi-Fi at primary schools with children under the age of 11 only when used specifically for lessons. Public places offering Wi-Fi must clearly advertise this fact on a sign. At the point of sale of mobile phones, the SAR value must be clearly shown. In the future, any mobile phone advertisement must include recommendations on how users can reduce RF radiation exposure to the head such as the use of headsets. Data on local EMF exposure levels shall be made more easily acces-sible to the general public, among others, through country-wide transmitter maps. Also, the French government will have to submit a report on electromagnetic hypersensitiv-ity to the parliament within a year (45).

As of February 2016, 220 scientists from 42 coun-tries have signed an international Appeal, directed to the United Nations (UN) and WHO, calling for protec-tion from non-ionizing electromagnetic field exposure. The appeal addresses the scientifically proven effects on health and the inadequate international guidelines (ICNIRP) to date and their use by the WHO. In addition, nine requests were made, including that: “the public be fully informed about the potential health risks from elec-tromagnetic energy and taught harm reduction strategies” and that “medical professionals be educated about the biological effects of electromagnetic energy and be pro-vided training on treatment of patients with electromag-netic sensitivity” (46).

In September 2015 an International Scientific Decla-ration on Electromagnetic Hypersensitivity and Multiple Chemical Sensitivity was published by the Scientific Com-mittee following the 5th Paris Appeal Congress, which took place on 18 May 2015 at the Royal Academy of Medi-cine, Brussels, Belgium. It calls upon national and inter-national agencies and organizations to recognize EHS and multiple chemical sensitivity as a disease and urges par-ticularly the WHO to include EHS and MCS in the Interna-tional Classification of Diseases. It also asks national and international agencies and organizations to adopt simple precautionary measures of prevention, to inform the public, and to appoint truly independent expert groups to evaluate these health risks based on scientific objectivity, which is not the case today (47).

EMF and cancer

Except for a few investigations in occupational settings, epidemiological research of EMF started in 1979 when Wertheimer and Leeper published their study about the relationship between the proximity to so-called power line poles (ELF MF) with “service drop” wires and the occurrence of childhood cancer (specifically leukemia and brain tumors) (48). At the same time Robinette et al. studied mortality in a cohort of Korean War veterans having been trained on military radars (RF) in the early 1950s (49). Both studies found indications of increased risks and initiated a new era of studying health-relevant effects from exposure to EMFs.

ELF MF

In the following years, a large number of investigations about the relationship between childhood leukemia and extremely low frequency magnetic fields (ELF MF) have been published. However, the results seemed inconsist-ent until in 2000 two pooled analyses (50, 51) were con-ducted, providing little indication of inconsistency and demonstrating an increase of leukemia risk with increas-ing average exposure levels that was significant for levels above 0.3 or 0.4 µT relative to averages below 0.1 µT but without indication of a threshold. Based on these find-ings, the International Agency for Research on Cancer (IARC) classified ELF MF in 2002 as a Group 2B (possible) carcinogen (30). To this category belong, e.g. lead, DDT, welding fumes, and carbon tetrachloride.

Since then additional epidemiological studies have been conducted that gave essentially the same results (52, 53). The only study to date on the gene-environment interaction in relation to power-frequency MF reported a significant effect enhancement in children with a poly-morphism in a DNA-repair gene (54). In a review on child-hood leukemia and ELF MF, Kundi concluded that there is sufficient evidence from epidemiological studies of an increased risk for childhood leukemia from exposure to power-frequency MF that cannot be attributed to chance, bias, or confounding. Therefore, according to the rules of IARC, such exposures ought to be classified as a Group 1 (definitive) carcinogen (55).

The BioInitiative Report 2012 (56) stated: “Children who have leukemia and are in recovery have poorer sur-vival rates if their ELF exposure at home (or where they are recovering) is between 1mG [0.1 µT] and 2 mG [0.2 µT] in one study; over 3 mG [0.3 µT] in another study” (56).


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RF

There were several mechanisms identified which might be responsible for carcinogenic effects of RF (23). Epidemio-logical studies of RF before the general rise in exposure to mobile telecommunication devices was very restricted and only a few studies had been conducted in the vicin-ity of radio transmitters, radar stations, for occupational exposures, and in radio amateurs. After the introduction of digital mobile telephony, the number of users of mobile phones increased dramatically and it was recommended in the 1990s to perform epidemiological studies with a focus on intracranial tumors. Since the first publication in 1999 by the Swedish group of Prof. Lennart Hardell (57), about 40 studies have been published. The majority of these studies investigated brain tumors, but salivary gland tumors, uveal melanoma, malignant melanoma of the skin, nerve sheath tumors, testicular cancer, and lymphoma were also studied. Many of these studies are inconclusive because exposure durations are too short; however, two series of investigations, the international Interphone Study conducted in 13 countries and the Swedish studies of the Hardell group, had a significant proportion of long-term mobile phone users and could in principle be used for risk assessment. In 2011, IARC classified radio-frequency electromagnetic fields (RF) as a Group 2B carcinogen based on evidence from epide-miological studies and animal experiments (24). Since then, additional studies have corroborated the assump-tion of a causal relationship between mobile phone use and cancer (58–60). Hardell and Carlberg (61) concluded that RF EMF ought to be classified as a definitive human carcinogen (IARC Group 1). The evidence for a causal rela-tionship between long-term mobile and cordless phone use and the risk of glioma has increased further: in 2014, a study by Carlberg and Hardell (62) showed significantly decreased survival rates in patients with glioblastoma multiforme (astrocytoma grade IV) and the use of wireless phones and, in 2015, another pooled case-control study by Hardell and Carlberg (63) including latency periods of > 25 years.

That also other tumors might be related to EMF expo-sure is exemplified by the observation in women who have worn their mobile phone in their bra for prolonged periods of time and later developed breast cancer at that site (64).

The Italian Supreme Court confirmed a previous deci-sion by the Civil Court of Appeals of Brescia (no. 614 of 10 December 2009) that ruled that the National Institute for Workmen’s Compensation (INAIL) must compensate a worker who had developed a tumor in the head due to long-term, heavy use of mobile phones while on the job.

The case was an ipsilateral neuroma of the trigeminal nerve in a subject who had occupational exposure for > 10 years, with > 15,000 h on mobile and cordless phones. The court recognized that “it is likely (qualified probabil-ity) that RF have a role which is at least contributory in the development of the origin of the tumor suffered by the subject” (65).

Many modern devices emit EMF of different frequency ranges simultaneously. For example, mobile phones create EMF in RF, VLF, and ELF frequency ranges and also a static magnetic field; for a review see (23). Therefore, it is important to consider combined exposures for the assess-ment of health effects.

Genotoxic effects

Genotoxic effects of EMF dealing with DNA damage, mutations, chromatin structure, and DNA repair have recently been reviewed by Henry Lai in the Bioinititive Report (66) and by the IARC Working Group in the assess-ment of RF carcinogenicity (24). In general, about half of the available studies found genotoxicity (positive reports), although other studies did not (negative reports) (23). Of note, a similar ratio of positive and negative RF studies was reported for other biological endpoints (67–69). The evident reason for this eventual inconsistency is strong dependence of the EMF effects on a number of physical and biological parameters, which significantly varied between studies. These dependencies were established for both ELF (70–72) and RF effects (24, 27).

Among other parameters, in human lymphocytes, an individual variability in chromatin response to ELF has been reported, which might suggest a stronger response in cells from EHS individuals (72). The same research group performed comparative studies on genotoxicity with cells from EHS and carefully matched control subjects (73–75). The response of lymphocytes to RF from GSM mobile phones (915 MHz) and power-frequency magnetic fields (50 Hz) was investigated (73). The 53BP1 protein, which participates in the formation of DNA repair foci at the loca-tion of DNA double-strand breaks (DSB), was analyzed by immunostaining in situ. Exposure to either 915 MHz or 50 Hz significantly condensed chromatin and inhibited the formation of DNA repair foci. The EMF-induced responses in lymphocytes from healthy and hypersensitive donors were similar but not identical to the stress response induced by heat shock. The effects of GSM on chroma-tin and DNA repair foci in lymphocytes from EHS were further confirmed (74, 75). Although individual variability was observed, effects of RF from mobile phones strongly


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depended on the carrier frequency/frequency channel (74–77). Regardless of the cell type (human lymphocytes, fibroblasts, or stem cells), the effects at the 905 MHz/GSM channel 74 on DNA repair foci and chromatin were consistently lower as compared to the effects at the 915 MHz/GSM channel 124. The data also indicated stronger effects of exposure to RF from UMTS mobile phone radia-tion at the frequency of 1947.4 MHz. These data provided evidence that different frequency channels of different types of mobile communications technologies should be tested separately in provocation studies with EHS. While some minor differences were detected, very similar ELF/RF effects were observed in cells from EHS and matched control subjects. It is likely that compensatory reactions at a more complex level of biological organization such as reactions of tissues, organs, and organ systems are less efficient in persons with EHS, thereby providing a stronger connection of the EMF cellular response with symptoms of hypersensitivity.

Neurological effects of EMF

Neurological and behavioral effects were among the ear-liest topics of research on potential adverse effects of ELF as well as RF EMFs (78, 79). Concerning epidemiological evidence, more than a decade before the seminal publi-cation of Wertheimer and Leeper (48), Haynal and Regli reported in 1965 an approximately four-fold higher preva-lence of a history of electrical engineering jobs in patients with amyotrophic lateral sclerosis (ALS) than in control subjects (80).

Functional, morphological, and biochemical changes at the cellular, tissue, and organism level, as well as behavioral changes have been studied under experimen-tal conditions, and epidemiology has assessed the asso-ciation between occupational and residential exposure to EMFs and neurodegenerative diseases as well as neuro-logical symptoms.

Research has shown that EMFs (RF and ELF) have deleterious effects on brain neurons and brain function-ing (81). Epidemiological research has also shown an increased risk for Alzheimer’s and dementia from occupa-tional and residential exposure to ELF.

Neurological effects of radio-frequency radiation

Early studies of RF are difficult to assess because the descriptions of exposure conditions are often insufficient to derive the relevant dosimetric quantities. As early as

1932, Schliephake (82) reported effects that he considered to be non-thermal: „Es treten Erscheinungen auf, wie wir sie bei Neurasthenikern zu sehen gewohnt sind: starke Mattig-keit am Tag, dafür in der Nacht unruhiger Schlaf, zunächst ein eigenartig ziehendes Gefühl in der Stirn und Kopfhaut, dann Kopfschmerzen, die sich immer mehr steigern, bis zur Unerträglichkeit. Dazu Neigung zu depressiver Stim-mung und Aufgeregtheit.“ [“Phenomena occur that we are accustomed to seeing in neurasthenics: pronounced fatigue during the day, however, restless sleep at night, in the beginning, a peculiar pulling sensation on the forehead and scalp, and then headaches that increase beyond the limit of tolerance. In addition, a tendency to depressive moods and agitation”.] Such symptoms, not unlike those later sum-marized as microwave or radio wave sickness syndrome, have been found in a substantial percentage of exposed workers in the Soviet Union (83) and also in individuals presenting as electrohypersensitive (see below).

Experimental research in humans was scarce before the advent of digital mobile telephony. Since the earliest studies (84, 85) on brain electrical activity, a large evidence base has been compiled that indicates subtle changes in CNS function after and during short-term exposure to different types of RF. Experimental investigations were predominantly about effects on EEG power spectra (e.g. 86–96), event related potentials (e.g. 97–104), sleep (e.g. 105–119) and cognitive function (e.g. 120–131). A few inves-tigations were about effects on glucose metabolism (132, 133) and regional cerebral blood flow (134, 135), applying PET scan imaging. Animal studies covered a wide variety of behavioral aspects, ranging from learning and memory (e.g. 136–141) to anxiety-related behavior (142).

The reaction of the CNS to RF is not restricted to the presence of the exposure but persists for some time after the exposure, making short-term cross-over studies unin-formative. The location of exposure could be of relevance under certain circumstances, but often effects are bilat-eral after unilateral exposure, suggesting involvement of subcortical structures. Effects on sleep may depend on individual characteristics, which led to the conclusion that conflicting results are not strong evidence against an effect (113). Pulsed RF is more effective than continuous waves, but there is some evidence of the importance of exposure characteristics including the site of coupling of the RF field and its modulation.

In the 2012 update of the BioInitiative Report, Henry Lai summarized the experimental evidence as follows (143): “Almost all the animal studies reported effects, whereas more human studies reported no effects than effects. This may be caused by several possible factors: (a) Humans are less susceptible to the effects of RFR than


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are rodents. (b) It may be more difficult to do human than animal experiments, since it is, in general, easier to control the variables and confounding factors in an animal experi-ment. (c) In the animal studies, the cumulative exposure duration was generally longer and studies were carried out after exposure, whereas in the human studies, the exposure was generally one time and testing was done during expo-sure. This raises the question of whether the effects of RFR are cumulative”.

Neurological effects of extremely low frequency electromagnetic fields (ELF EMF)

Neurophysiological investigations of ELF EMFs were already conducted in the 1970s. Studies of chick and cat brain tissue (e.g. 144–146) revealed effects of weak ELF EMFs and ELF modulated RF fields that depended on intensity and frequency (so-called window effects). Adey proposed in 1981 (147) that effects are due to a primary interaction of EMFs at the cell membrane surface inducing a cascade of intracellular processes. This early insight has been corroborated by recent studies on various transmitter receptors in the brain such as N-methyl-D-aspartate receptors, dopamine and serotonin receptors (e.g. 148–151). Some of these more recent studies also reported frequency window effects as well as intensity window effects on the neurodevelop-ment in the rat (152).

Behavioral effects of ELF EMF have been studied at rather high levels in the 1970s and 1980s (e.g. 153, 154), while recent studies include low-level exposures and support effects on behavior at different levels of complex-ity. These include: changes in locomotor activity (e.g. 148, 149, 155, 156), anxiety (e.g. 157–159) and depression-like behavior (160, 161). “Since different behavioral effects have been observed in different exposure conditions, species of animals, and testing paradigms, they provide the strongest evidence that exposure to ELF EMF can affect the nervous system”. (Lai, 2012, BioInitiative Report, section 9, Evidence for effects on neurology and behavior effects, 143). Also in humans, effects were reported at low levels (e.g. 162–164).

Neurodegenerative diseases

The most prevalent of neurodegenerative diseases is Alzheimer’s disease with an estimated 45 million patients worldwide for 2015, followed by Parkinson’s disease, Huntington’s disease, amyothrophic lateral sclerosis (ALS), and other motoneuron diseases (MND). To date,

the pathophysiology of these diseases is incompletely understood. In many of these diseases, atypical protein assemblies, mitochondrial dysfunction, and programmed cell death play a role and some genetic changes have been detected. As some such changes could be a consequence of oxidative stress (see below), disruption of calcium homoeostasis, and disturbance of intracellular signal-ing pathways, there is a theoretical possibility that EMFs could contribute to the risk of these diseases. Since the 1980s, more than 30 epidemiological studies assessing the potential relationship between exposure to ELF EMFs and neurodegenerative diseases have been conducted. In the last years, several meta-analyses have been published. Concerning Parkinson’s disease, there is little evidence of an association (165). Concerning ALS, Zhou et al. (166) summarize their results as follows: “Although there are potential limitations from study selection bias, exposure misclassification, and the confounding effect of individual studies in this meta-analysis, our data suggest a slight but significant ALS risk increase among those with job titles related to relatively high levels of ELF EMF exposure”. A review by Vergara et al. came to another conclusion (167): “Our results do not support MF [magnetic fields] as the explanation for observed associations between occupa-tional titles and MND”. This discrepancy can be resolved by discriminating between different methods of endpoint assessment (incidence, prevalence or mortality data) and the potential for misclassification due to various sources of exposure data used. If these factors are considered, there is a consistent relationship between ELF EMF from occupational exposure and ALS/MND, and also the few studies about residential exposure are in line with an increased risk from exposure to MF (168).

Blood-brain barrier

All exchanges between blood and brain are strictly regu-lated by the blood-brain barrier (BBB). The BBB prevents the passage of various molecules from the blood into the brain and vice versa. An increase in a normally low BBB permeability for hydrophilic and charged molecules could potentially be detrimental. While the data on ELF effects are very sparse, several research groups investigated whether RF affects the BBB. These data have recently been reviewed (169–171). Although some BBB studies reported negative data, other studies, including replicated studies with rats from the Swedish group of Leif Salford and Bertil Persson, suggested that RF from mobile phones may affect the BBB under specific exposure conditions (171). More recent studies showing EMF effects at specific conditions of


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exposure (150, 172, 173) and not showing effects on the BBB under other conditions (174) are in line with this suggestion.

EMF and infertility and reproduction

Infertility and reproduction disorders are on the rise. Based on the BioInitiative Report (175), it should be con-cluded that men who use – and particularly those who wear a mobile phone, personal digital assistant (PDA) or pager on their belt or in a pocket – show adverse effects on sperm quality, motility, and pathology. The usage of mobile phones, the exposure to mobile phone radiation, or the storage of a mobile phone close to the testes of human males affects sperm count, motility, viability, and structure (176–184). Animal studies have demonstrated oxidative and DNA damage, pathological changes in the testes of animals, decreased sperm mobility and viability, and other measures of deleterious damage to the male germ line (182, 185–188).

There are also some studies of adverse birth outcomes in EMF-exposed women. A case-control study (189) and a population-based prospective cohort study (190) from California showed an association between miscarriage and the maximum value measured by a 24-h body-worn magnetic field dosimeter.

Electromagnetic hypersensitivity (EHS)

An increasing number of humans are continuously exposed in their daily life to increasing levels of a com-bination of static, ELF and VLF (very low frequencies, in general terms from 3 kHz to 3 MHz, in detailed terms from 3 kHz to 30 kHz) electric and magnetic fields and RF electromagnetic fields. These exposures are of different signal patterns, intensities, and technical applications for varying periods of time. All these fields are summarized as EMF, colloquially referred to as “electrosmog”.

Some historical examples of EHS from as early as 1932 (82, 83) are given in the chapter “Neurological effects of radio-frequency radiation”.

In a questionnaire survey in Switzerland in 2001, which was addressed to persons attributing specific health prob-lems to EMF exposure, of the 394 respondents 58% suffered from sleep problems or disorders, 41% from headaches, 19% from nervousness, 18% from fatigue, and 16% from difficulties with concentration. The respondents attributed their symptoms to, e.g. mobile phone base stations (74%), mobile phones (36%), cordless phones (29%), and high-voltage power lines (27%). Two thirds of the respondents

had taken measures to reduce their symptoms, the most frequent one being to avoid exposure (191).

In 2001, 63 persons who attributed health problems to environmental exposure were counseled in an interdis-ciplinary environmental medicine pilot project in Basel. An interdisciplinary expert team assessed the individual symptoms by a medical psychological-psychiatric and environmental examination, including visits and envi-ronmental measurements at home. With respect to the 25 persons with EHS, the expert team attested to the fact that in one third of them at least one symptom was plausibly related to electrosmog, although the EMF exposure was within the Swiss limits. They concluded that patients with EHS should be advised medically, psychologically, and environmentally (192, 193).

A questionnaire study of Finns (n = 206), who describe themselves as suffering from electromagnetic hypersensi-tivity (EHS), revealed that the most common symptoms were related to the nervous system: stress (60%), sleep-ing disorders (59%) and fatigue (57%). The sources that were most often reported to have triggered EHS were: personal computers (51%) and mobile phones (47%). For 76% of the participants the reduction or avoidance of electromagnetic fields (EMF) helped in their full or partial recovery (194).

A representative telephone survey (n = 2048; age > 14 years) carried out in Switzerland in 2004 yielded a fre-quency of 5% (95% CI 4% to 6%) for having symptoms attributed to electrosmog, so-called EHS. In n = 107 EHS persons, the most common symptoms being sleep prob-lems (43%), headache (34%), and concentration difficul-ties (10%). Remarkably, only 13% consulted their family doctor. Individuals with a past history of symptoms attrib-utable to EMF gave “turned off the source” as the answer to measures taken three times as often as the ones who still had symptoms (195).

In a Swiss questionnaire study of GPs in 2005, two-thirds of the doctors were consulted at least once a year because of symptoms attributed to EMF. Fifty-four percent of the doctors assessed a relation as possible. The doctors in this questionnaire asked for more general information about EMF and health and instructions on how to deal with patients with EHS (196).

In another questionnaire study, also mandated by the Swiss Federal Government and performed by the Univer-sity of Bern in 2004, Swiss doctors working with comple-mentary diagnostic and therapeutic tools reported that 71% of their consultations related to EMF. Remarkably, not only the patients but even more so the doctors suspected a possible relation between illness and EMF. The reduction or elimination of environmental sources was the main


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therapeutic instrument in treating symptoms related to EMF (197).

A questionnaire study of Austrian doctors yielded similar results. In this study, the discrepancy between the physicians’ opinions and established national and inter-national health risk assessments was remarkable, consid-ering that 96% of the physicians believed to some degree in or were totally convinced of a health-relevant role of environmental electromagnetic fields (198).

In a survey conducted 2009 in a Japanese EHS and multiple chemical sensitivity (MCS) self-help group (n = 75), 45% of the respondents had EHS as a medical diag-nosis and 49% considered themselves EHS. Every second respondent had medically diagnosed MCS (49%) and 27% had self-diagnosed MCS. The main EHS-related symptoms were fatigue, headache, concentration problems, sleep dis-orders, and dizziness. The most frequent causes included base stations, other persons’ mobile phones, PC, power lines, television, own mobile phone, public transporta-tion, cordless phones, air conditioner, and car. Suspected EMF source of EHS onset were: mobile phone base sta-tions, PC, electric home appliances, medical equipment, mobile phones, power lines, and induction cookers (199).

In 2010, Khurana et al. reported that eight out of ten epidemiological studies that assessed health effects of mobile phone base stations reported an increased preva-lence of adverse neurobehavioral symptoms or cancer in populations living at distances within 500 m from base stations. None of the studies reported exposure levels above accepted international guidelines, suggesting that current guidelines may be inadequate in protecting the health of human populations (200).

Carpenter reported in 2015 (201) a series of healthy people that developed EHS after a brief, high- intensity microwave radiation exposure. Typical symptoms included, for example, chronic headaches, irritability, and emotional lability, decreased libido, and memory problems, which in some patients, lasted for years.

Hedendahl et al. (19) reported two 15-year-old male students and one 47-year-old female teacher who experi-enced health effects like headaches, difficulties concen-trating, tachycardia, poor memory, or dizziness when exposed to Wi-Fi in school. This example is mentioned to point specifically to the potential health impacts from increasing RF exposure of students and teachers by Wi-Fi.

The question, whether EHS is causally associated with EMF exposure is controversially discussed. On the one hand, physicians judge a causal association between EMF exposures as plausible based on case reports, on the other hand, national and international health risk assessments mostly claim that there is no such causal association,

because provocation studies under controlled blinded conditions mostly failed to show effects. However, these studies have severe shortcomings that must be addressed: sequences of exposure conditions were often contiguous neglecting aftereffects of exposure; the exposure duration and the examined effects were short-term; the sham expo-sure was frequently under conditions that could provoke arousal in sensitive individuals; the time frame neglected the temporal conditions of symptom occurrence and dis-appearance, and/or the recruitment of persons with EHS was not medically assessed.

The WHO does not consider EHS as a diagnosis and rec-ommends to medical doctors that the treatment of affected individuals should focus on the health symptoms and the clinical picture, and not on a person’s perceived need for reducing or eliminating EMF in the workplace or at home (202). Based on the existing evidence and practical knowl-edge this view ignores a causal approach; see also (203).

The paper “Electromagnetic hypersensitivity: fact or fiction” by Genuis and Lipp (204) offers an instructive review of studies of the last decades concerning EHS, including historical milestones, reviews, pathogenesis, biochemical markers, therapeutic management, as well as the debate about the legitimacy of EHS.

In facial skin samples of electrohypersensitive persons, a profound increase of mast cells has been found (205). From this and other earlier studies when EHS mani-fested itself often during exposure to EMFs from cathode ray tubes (CRT), it became clear that the number of mast cells in the upper dermis is increased in the EHS group. A different pattern of mast cell distribution also occurred in the EHS group. Finally, in the EHS group, the cytoplas-mic granules were more densely distributed and more strongly stained than in the control group, and the size of the infiltrating mast cells was generally found to be larger in the EHS group as well. It should be noted that increases of a similar nature were later demonstrated in an experi-mental situation, employing normal healthy volunteers in front of CRT monitors, including ordinary household tel-evision sets (206).

A French research group headed by Belpomme (207) investigated prospectively, since 2009, self-reported cases of EHS and/or MCS clinically and biologically in an attempt to establish objective diagnostic criteria and to elucidate the pathophysiological aspects of these two disorders. Based on 727 evaluable cases, the investigation showed a number of new and important insights such as:(a) None of the biomarkers so far identified in the study

are specific for EHS and/or MCS.(b) Several biomarkers like histamine, nitrotyrosine,

and circulating antibodies against O-myelin were


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increased. The 24-h urine melatonin/creatinine ratio was decreased.

(c) EHS and MCS are genuine somatic pathological entities.

(d) Under the influence of EMFs and/or chemicals a cer-ebral hypoperfusion/hypoxia-related neuroinflam-mation may occur.

(e) EHS and/or MCS patients might be potentially at risk of chronic neurodegenerative diseases and cancer.

While a 2006 study by Regel et al. (208) described no expo-sure effects, two provocation studies on exposure of “elec-trosensitive” individuals and control subjects to mobile phone base station signals (GSM, UMTS, or both) found a significant decline in well-being after UMTS exposure in the individuals reporting sensitivity (209, 210). Most so-called provocation studies with EHS show no effects. However, all these studies used a very limited number of exposure conditions and most have methodological weak-nesses. Taking in account the strong dependence of EMF effects on a variety of physical and biological variables (27), available provocation studies are scientifically diffi-cult to interpret and, in fact, are not suitable to disprove causality.

There is increasing evidence in the scientific literature of various subjective and objective physiological altera-tions, e.g. heart-rate variability (HRV) as apparent in some persons with EHS claiming to suffer after exposure to certain frequencies of RF like DECT or Wi-Fi (211–215). Analysis of the data available on the exposure of people living near mobile phone base stations has yielded clear indications of adverse health effects like fatigue, depression, difficulty in concentrating, headaches, dizziness, etc. (216–220). A syn-opsis of 30 studies on mobile phone base stations is given in the document “Leitfaden Senderbau” (221).

Residential EMF exposures in the VLF frequency range are often due to “dirty power”/“dirty electricity” origi-nating from voltage and/or current perturbations from diverse sources like electronic power supplies for TVs, monitors, PCs, motor drives, inverters, dimmers, compact fluorescent lamps (CFLs), phase-angle control devices, as well as sparking and arcing from switching operations and from electric motors with brushes. The kHz waves/transients travel along the electric wiring and grounding systems (conducted emissions) and radiate electric and/or magnetic fields into free space (radiated emissions), leading to human exposures in the vicinity.

First epidemiological evidence links dirty electricity to most of the diseases of civilization including cancer, cardiovascular disease, diabetes, suicide, and attention deficit hyperactivity disorder in humans (222).

While the dependence of ELF effects on the local mag-netic field has been reported by many research groups (13, 223), there are also a few studies which suggest that the RF effects are also dependent on slight changes in the local static magnetic field. In the review by Belyaev (224), a physical mechanism has been suggested to account for such effects (225). Slight changes in the local static mag-netic field within 10 µT, which are usually observed within offices and homes due to ferromagnetic objects, were reported to induce biological effects that corresponded well to the predictions following from the mechanism of ion interference developed by Binhi (226).

On July 8, 2015, a court in Toulouse, France, ruled in favor of a woman with the diagnosis “syndrome of hyper-sensitivity to electromagnetic radiation” and determined her disability to be 85% with substantial and lasting restrictions on access to employment (227).

In France, the first low-EMF zone has been established at Drôme in July 2009 (228). In Austria, the construction of a multi-family house has been planned for 2015, which was designed by a team of architects, building biology professionals, and environmental medicine health care professionals to provide a sustainable healthy living envi-ronment. Both the outdoor and indoor environments were explicitly chosen and designed to meet low-EMF require-ments (229). The implementation of low-EMF zones for electrosensitive individuals is pursued in numerous coun-tries. The realization of such projects greatly depends on the understanding, knowledge, and tolerance of the members of the chosen community.

Possible mechanism of EHS

Based on the scientific literature on interactions of EMF with biological systems, several mechanisms of interac-tion are possible (14, 13, 22, 26). A plausible mechanism at the intracellular and intercellular level, for instance, is an interaction via the formation of free radicals or oxidative and nitrosative stress (230–238). It has been shown in many reports reviewed by Georgiu (15) that reactive oxygen species (ROS) may be involved in radical pair reactions; thus, radical pairs may be considered as one of the mechanisms of transduction able to initiate EMF-induced oxidative stress. Furthermore, many of the changes observed in RF-exposed cells were prevented by (pre)treatment with antioxidants and radical scaven-gers (24). While the data from different studies should be interpreted with care in view of variations in physical and biological parameters, a majority of the studies have shown effects of ELF and RF on the oxidative stress (239).


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The IARC monograph states: “even small effects on radical concentration could potentially affect multiple biological functions”, page 103 (24).

Yakymenko et al. (238) have summarized the current evidence: “Analysis of the currently available peer-reviewed scientific literature reveals molecular effects induced by low-intensity RFR in living cells; this includes significant activation of key pathways generating reactive oxygen species (ROS), activation of peroxidation, oxidative damage of DNA and changes in the activity of antioxidant enzymes. It indicates that among 100 currently available peer-reviewed studies dealing with oxidative effects of low-intensity RFR, in general, 93 confirmed that RFR induces oxidative effects in biological systems. A wide pathogenic potential of the induced ROS and their involvement in cell signaling pathways explains a range of biological/health effects of low-intensity RFR, which include both cancer and non-cancer pathologies”.

Reviews by Pall (12, 16, 240) provide evidence for a direct interaction between static and time-varying electric fields, static and time-varying magnetic fields and elec-tromagnetic radiation with voltage-gated calcium chan-nels (VGCCs). The increased intracellular Ca2+ produced by such VGCC activation may lead to multiple regulatory responses, including increased nitric oxide levels pro-duced through the action of the two Ca2+/calmodulin-dependent nitric oxide synthases, nNOS and eNOS. In most pathophysiological contexts, nitric oxide reacts with superoxide to form peroxynitrite, a potent non-radical oxidant, which can produce radical products, including hydroxyl and NO2 radicals.

Peroxynitrite is by far the most damaging molecule that occurs during metabolism in our body. Although not a free radical, peroxynitrite is much more reactive than its parent molecules NO and −

2 .O The half-life of peroxynitrite is com-paratively long (10–20 ms), sufficient to cross biological membranes, diffuse one to two cell diameters, and allow significant interactions with most critical biomolecules and structures (cell membranes, nucleus DNA, mitochondrial DNA, cell organelles), and a large number of essential met-abolic processes (225). Elevated nitrogen monoxide, forma-tion of peroxynitrite, and induction of oxidative stress can be associated with chronic inflammation, damage of mito-chondrial function and structure, as well as loss of energy, e.g. via the reduction of adenosine triphosphate (ATP).

A significant increase of 3-nitrotyrosine was observed in the liver of Wistar rats exposed to ELF, suggesting a deteriorative effect on cellular proteins due to possible formation of peroxynitrite (241). Nitrotyrosin was found to be increased ( > 0.9 µg/mL) in 30% of the 259 tested EHS individuals (207).

A study by De Luca et al., in 2014 on 153 EHS and 132 controls showed metabolic pro-oxidant/pro-inflammatory alterations in EHS like decreased erythrocyte glutathione S-transferase (GST) activity, decreased reduced glu-tathione (GSH) levels, increased erythrocyte glutathione peroxidase (GPX) activity, an increased ratio of oxidized-CoQ10/total-CoQ10 in plasma, and a 10-fold increased risk associated with EHS for the detoxifying enzymes glutathione S transferase haplotype (null) GSTT1+(null) GSTM1 variants (242).

The importance of ATP has been shown for chronic fatigue syndrome (CFS) (243) and for stress control (244). Those patients describe the same symptoms as those suf-fering from CMI. This could indicate similarities in their pathomechanisms. Similar disturbances in neurotrans-mitter expression has been described both with chronic exposure to EMF (245) and in CMI patients (232, 246).

A study (247) proposed to investigate a possible asso-ciation between RF exposure and myelin integrity via classical immunohistochemical markers for healthy and degenerated myelin, respectively, and for Schwann cells in general.

Complaints in chronic fatigue syndrome (CFS), fibro-myalgia (FM), multiple chemical sensitivity (MCS), post-traumatic stress disorder (PTSD), and Gulf War syndrome (GWS) are almost the same. Meanwhile, they are summa-rized as chronic multisystem illnesses (CMI) (246). In all of them, various disturbances of functional cycles have been shown: activation of nitrogen oxide and peroxynitrite, chronic inflammation by activation of NF-kB, IFN-y, IL-1, IL-6, and interaction with neurotransmitter expression (232, 246, 248). We recommend classifying EHS as part of CMI (232, 249), but still recognizing that the underlying cause remains the environment (see Figure 1).

Other diseases that require attention with respect to EMFBased on interactions between EMF exposure and biologi-cal responses that, e.g. lead to a disturbance of the oxi-dative/nitrosative homeostasis, a variety of diseases are possible and even expected to occur. Some examples are given here.

Havas reported in 2008 (250): “Transient electromag-netic fields (dirty electricity), in the kilohertz range on elec-trical wiring, may be contributing to elevated blood sugar levels among diabetics and prediabetics. By closely follow-ing plasma glucose levels in four Type 1 and Type 2 diabetics, we find that they responded directly to the amount of dirty electricity in their environment. In an electromagnetically


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clean environment, Type 1 diabetics require less insulin and Type 2 diabetics have lower levels of plasma glucose. Dirty electricity, generated by electronic equipment and wireless devices, is ubiquitous in the environment. Exercise on a treadmill, which produces dirty electricity, increases plasma glucose. These findings may explain why brittle diabetics have difficulty regulating blood sugar. Based on estimates of people who suffer from symptoms of electrical hypersensitivity (3%–35%), as many as 5–60 million dia-betics worldwide may be affected”.

With respect to fetal and early childhood exposures to EMF, Sage in the BioInitiative Report 2012 (56) pointed out: “Fetal (in-utero) and early childhood exposures to cell phone radiation and wireless technologies in general may be a risk factor for hyperactivity, learning disorders and behavioral problems in school.” [&] “Common sense meas-ures to limit both ELF EMF and RF EMF in these populations is needed, especially with respect to avoidable exposures like incubators that can be modified; and where education of the pregnant mother with respect to laptop computers, mobile phones and other sources of ELF EMF and RF EMF are easily instituted”.

In a 2013 review, Herbert and Sage (251, 252) reported remarkable similarities between pathophysiological phe-nomena found in autism spectrum conditions (ASCs) and the physiological impacts of ELF MF/RF, such as oxida-tive stress, free radical damage, malfunctioning mem-branes, mitochondrial dysfunction, inflammatory issues, neuropathological disruption and electrophysiological dysregulation, cellular stress proteins and deficiencies of antioxidants such as glutathione.

In a 6-year study, certain blood hormone levels were monitored in volunteers. Mobile phone use as well as close distances to mobile phone base stations were associated

MetalsIndustrial pollutants

PesticidesFungi

TraumataBacteria

Viruses

Nitrosative stressNitric oxide ↑

Peroxynitrite ↑Superoxid ↑ iNOS ↑

MitochondriopathyATP ↓

Solvents

EMFPlastizisers

Food

InflammationImpairedImmuneTolerance

Oxidativestress

TNF-αInterferon-γHYistamine

Severe psycho-social stress

TH2 dominanceLoss ofTreg cells

Figure 1: Pathogenesis of inflammation, mitochondriopathy, and nitrosative stress as a result of the exposure to trigger factors (248).

with decreased testosterone levels in males, as well as decreased ACTH, cortisol, T3 and T4 levels in males and females (253).

Recommendations for actionEUROPAEM has developed guidelines for differential diag-nosis and potential treatment of EMF-related health prob-lems with the aim to improve/restore individual health outcomes and to propose strategies for prevention. These recommendations are further outlined below.

These recommendations are preliminary and in large parts, although related to the whole body of evidence rooted in the experience of the team, cannot in every detail be strictly considered evidence-based.

Evidence of treatment strategies for EMF-related illness including EHSThere are only a few studies assessing therapeutic approaches to EHS. The interdisciplinary based assessing and counseling of EHS in the Swiss Environmental Pilot Project performed in 2001 showed, in an evaluation inter-view half a year after counseling, that 45% of the persons with EHS had benefitted from realizing certain advice, e.g. changing the bedroom (192, 193).

In the 2005 Swiss questionnaire study of physi-cians working with complementary therapeutic tools, two-thirds chose exposure reduction as a principal tool, whereas complementary therapeutics were only chosen as a supplement (197).

Since 2008, the Swiss Society of Doctors for the Envi-ronment has run a small interdisciplinary environmen-tal medicine counseling structure for patients with EHS, which is embedded in everyday practice with a central coordination and consultation office as well as a network of general practitioners interested in environmental medi-cine who perform environmental medical assessments and consultations based on a standard protocol. If nec-essary, environmental experts are consulted and home inspections are conducted. The aim of the assessments is to detect or rule out common diseases and to analyze the impact of suspected environmental burdens on the com-plaints in order to find individual therapeutic approaches. The main instrument of the assessment is an extensive medical and psycho-social history with an additional environmental history, including a systematic question-naire and environmental key questions.


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In the first years, the project was scientifically assessed. In a questionnaire 1 year after counseling, 70% of the persons recommended the interdisciplinary based counseling structure and 32% of them considered the counseling as being helpful. Therefore, a model based on such an interdisciplinary concept, embedded in the family doctor’s holistic and lasting concept of treatment, seems to be promising for a better therapeutic approach to EHS, also including accessibility measures targeted at the actual environment (254).

In Finland, psychotherapy is the officially recom-mended therapy for EHS. In a questionnaire study of EHS people in Finland, symptoms, perceived sources and treatments, the perceived efficacy of medical and complementary alternative treatments (CAM) in regards to EHS were evaluated by multiple choice questions. According to 76% of the 157 respondents, the reduc-tion or avoidance of EMF helped in their full or partial recovery. The best treatments for EHS were given as weighted effects: dietary change (69.4%), nutritional supplements (67.8%), and increased physical exercise (61.6%). The official treatment recommendations of psychotherapy (2.6%) were not significantly helpful, or for medication (–4.2%) even detrimental. The avoid-ance of electromagnetic radiation and fields effectively removed or lessened the symptoms in persons with EHS (194, 255).

Response of physicians to this development

In cases of unspecific health problems (see Questionnaire) for which no clearly identifiable cause can be found – besides other factors like chemicals, non-physiological metals, molds – EMF exposure should, in principle, be taken into consideration as a potential cause or cofactor, especially if the person presumes it.

A central approach for a causal attribution of symp-toms is the assessment of variation in health problems depending on time and location and individual suscep-tibility, which is particularly relevant for environmental causes such as EMF exposure.

Regarding such disorders as male infertility, mis-carriage, Alzheimer’s, ALS, blood sugar fluctuations, diabetes, cancer, hyperactivity, learning disorders and behavioral problems in school, it would be important to consider a possible link with EMF exposure. Some people with EHS might be misdiagnosed with multiple sclerosis (MS) since many of the symptoms are similar. This offers an opportunity to causally influence the course of the disease.

Differential diagnosis includingdiagnostic tests

Assessment of EMF exposure

Take special medical history, including the assessment of symptoms, diseases, and circumstances regarding the times and places of appearance of symptoms

(see Annex Patient Questionnaire)

Reduction and preventionof EMF exposure

EMF exposure presented by the patient/person or

EMF exposure suspected by the physician

Relevance and conclusion

Possible associationwith EMF

Association with other environmental factors

Reduction and prevention of other

environmental factors

No relevant associationwith environmental

factors

Consultation of other disciplines

Medical treatment

Figure 2: Flowchart for the handling of EMF-related health problems.

How to proceed if EMF-related health problems are suspectedThe recommended approach to diagnosis and treatment is intended as an aid and should, of course, be modified to meet the needs of each individual case (see Figure 2).1. History of health problems and EMF exposure2. Medical examinations and findings3. Measurement of EMF exposure4. Reduction and prevention of EMF exposure5. Diagnosis6. Treatment of the patient including the environment

History of health problems and EMF exposure

In order to put later findings into a larger context, a general medical history is necessary. Part of this history should include:

– Electrical trauma: multiple shocks, electrocution, struck by lightning.

– Chemical trauma: exposure to pesticides, metals, chlorinated hydrocarbons (PCBs, DDT, etc.)


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– Biological trauma in the form of a large load of parasites, fungal infections, viral infections, etc.

– Physical trauma to the central nervous system in the form of whiplash, other accidents, spinal problems

– Autoimmune disorders

In the next steps, we focus only on EMF-related health effects.

A questionnaire to take a systematic history of health problems and EMF exposure, compiled by the EUROPAEM EMF Working Group, is available in the Annex of this EMF Guideline.

The questionnaire consists of three sections:(a) List of symptoms(b) Variation of health problems depending on time,

location, and circumstances(c) Assessment of certain EMF exposures that can be

evaluated by questionnaire

The list of symptoms in the questionnaire serves to sys-tematically quantify health problems regardless of their causes. It also includes questions as to when the health problems first occurred. Most EMF-related symptoms are nonspecific and fall within the scope of health problems due to inadequate regulation (decompensation), e.g. sleep problems, fatigue, exhaustion, lack of energy, restless-ness, heart palpitations, blood pressure problems, muscle and joint pain, headaches, increased risk for infections, depression, difficulty concentrating, disturbances of coor-dination, forgetfulness, anxiety, urinary urgency, anomia (difficulty finding words), dizziness, tinnitus, and sensa-tions of pressure in the head and ears.

The health problems may range in severity from benign, temporary symptoms, such as slight headaches or paresthesia around the ear, e.g. when using a mobile phone, or flu-like symptoms after maybe some hours of whole-body EMF exposure, to severe, debilitating symp-toms that drastically impair physical and mental health. It has to be stressed that, depending on the individual state of susceptibility, EHS symptoms often occur only occa-sionally, but over time they may increase in frequency and severity. On the other hand, if a detrimental EMF exposure is sufficiently reduced, the body has a chance to recover and EHS symptoms will be reduced or will vanish.

Variation of health problems depending on time, location, and circumstancesThe answers to questions of when and where the health problems occur or recede, and when and where the symp-toms increase or are particularly evident, provide only

indications. They must be interpreted by the investigator (e.g. regarding the correct attribution between location/EMF sources and health problems). Special attention should be drawn to sleeping areas, because of the duration of influence and the vital role of sleep for regeneration.

Assessment of certain EMF exposures that can be evaluated by questionnaireThe assessment of EMF exposure usually starts with certain questions of usual EMF sources. Regardless of whether or not the patient suspects EMF exposure as a cause, these questions should be used to assess the existing exposure level, at least as a rough estimate. It is important to note that only certain types of EMF exposure can be assessed by means of questions, such as the use of compact fluorescent lamps, mobile phones, and cord-less phones. Detection of other types of EMF exposure, e.g. due to RF transmitter sites or the electric or magnetic fields from electric wiring, generally requires measure-ments. In principle, questions should be asked to assess EMF exposure at home and at work and when on holidays and so on, keeping in mind that the degree of EMF expo-sure may vary at different times.

Medical examinations and findings

We do not have any clinical findings yet that are specific to EMF, which makes diagnosis and differential diagnosis a considerable challenge.

A method that has proven useful is to use stress- associated findings for diagnosis and follow-up and to evaluate them synoptically. Basic diagnostic tests should be carried out as a first step, followed by measurements of EMF exposure as a second step. The core diagnosis should focus on investigations of nitric oxide production (nitroty-rosine), mitochondriopathy (intracellular ATP), oxidative stress-lipid peroxidation (MDA-LDL), inflammation [TNF-alpha, IFN-gamma-inducible protein 10 (IP-10), IL-1b, his-tamine], and the melatonin status (24 h urine melatonin/creatinine ratio).

Then additional diagnostic tests can be considered. Due to the differences in normal ranges between labs and different practices as to the units of measurement in dif-ferent countries, we do not provide levels to be considered relevant in EHS. It is recommended to interpret them in context, focusing not only on out-of-range values. For example, when several parameters are simultaneously close to the border of the normal ranges, this could be instructive for forming a therapeutic or diagnostic opinion.


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Functional testsBasic diagnostic tests

– Blood pressure and heart rate (in all cases resting heart rate in the morning while still in bed), including self-monitoring, possibly several times a day, e.g. at different locations and with journaling of subjective well-being for a week.

Additional diagnostic tests – 24-h blood pressure monitoring (absence of nighttime

decline) – 24-h ECG (heart rhythm diagnosis) – 24-h heart rate variability (HRV) (autonomous nerv-

ous system diagnosis) – Ergometry under physical stress – Sleep EEG at home

Laboratory testsBasic diagnostic tests

– Blood – ACTH – Bilirubin – Blood count and differential blood count – BUN – Cholesterol, LDL, HDL, triglycerides – Coenzyme-Q10 ratio for oxidized-CoQ10/total-CoQ10 – Creatinine kinases (CK-MB, CK-MM) – High-sensitivity C-reactive protein (hs-CRP) – Cystatin C (glomerular filtration rate) – Electrolytes – Fasting blood glucose – Ferritin – Glutathione S-transferase (GST) – Reduced glutathione (GSH) – Glutathione peroxidase (GPX) – HBA1c – Histamine and diaminoxidase (DAO) – IFN-gamma-inducible protein 10 (IP-10) – Interleukin-1 (e.g. IL-1a, IL-1b) – Intracellular ATP – Liver enzymes (e.g. ALT, AST, GGT, LDH, AP) – Magnesium (whole blood) – Malondialdehyde (MDA)-LDL – Nitrotyrosine (NTT) – Potassium (whole blood) – Prolactin – Selenium (whole blood) – Testosterone – TSH – T3, T4 – Tumor necrosis factor alpha (TNFα)

– Vitamin D3 – Zinc (whole blood)

– Standard urine – Leucocytes, erythrocytes, albumin, urobilinogen,

pH, bacteria, glucose, microalbumin – Second morning urine

– Adrenaline – Dopamine – Noradrenaline – Noradrenaline/adrenaline ratio – Serotonin – Beta-phenylethyleamine (PEA)

– 24-h urine – 6-OH melatonin sulfate – Creatinine – 6-OH melatonin sulfate/creatinine ratio

– Saliva – Cortisol (8 a.m., 12 a.m., and 8 p.m.)

Additional diagnostic tests – Urine

– Metals (depending on case history, e.g. mercury, cadmium, lead, arsenic, aluminum)

– Second morning urine – Gamma-aminobutyric acid (GABA) – Glutamate – Cryptopyrrole

– Saliva – Dehydroepiandrosterone DHEA (8 a.m. and 8 p.m.) – Alpha-amylase

– Blood – 8-Hydroxydeoxyguanosine (DNA oxidation) – Biotin – Differential lipid profile – Folate – Holotranscobolamin – Homocysteine – Interferon-gamma (IFN-γ) – Interleukin-10 (IL-10) – Interleukin-17 (IL-17) – Interleukin-6 (IL-6) – Interleukin-8 (IL-8) – Intracellular glutathione (redox balance) – Lactate, pyruvate incl. ratio – Lipase – NF-kappa B – Vitamin B6 (whole blood)

Provocation testsSpecial facilities with the use of a variety of signals, e.g. DECT or Wi-Fi exposure (e.g. 20–60 min, depending on


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the individual regulation capacity, susceptibility, and observed response)

– Heart rate variability (HRV) (autonomous nervous system diagnosis)

– Microcirculation – Oxidative stress (lipid peroxidation, malondialde-

hyde, oxo-LDL) – For diabetics, plasma glucose – Live blood analysis (red blood cell aggregation in the

form of rouleaux, blood viscosity, macrophage activ-ity, lysis of red blood cell membrane)

– For people with neurological problems and problems with fine or gross motor coordination, a video of them walking before and after provocation and a photo-graph taken of a sample of handwriting before and after provocation.

Individual susceptibility – Blood (genetic parameters and actual function)

– Glutathione S transferase M1 (GSTM1) – detoxifi cation – Glutathione S transferase T1 (GSTT1) – detoxification – Superoxide dismutase 2 (SOD2) – protection of

mitochondria – Catechol-O-methyltransferase (COMT) – stress

control

Measurement of EMF exposure

The evolutionary development of the human species took place under the presence of the natural electromagnetic spectrum (Earth’s magnetic field, Earth’s electric field, spherics, Schumann resonance). Those influences have been part of our biosphere like the oxygen content in the air or the visible light spectrum, and they have been inte-grated into the biological functions (14).

By now, nearly all non-ionizing parts of the electro-magnetic spectrum are filled with artificial, technical EMF sources due to electrification and (wireless) communica-tion technologies, but are very rarely found in nature (see Figure 3). EMF measurements and/or exposure damages are usually not covered by statutory health care insurance.

In general, a wide variety of EMF exposure types (static fields, ELF, VLF, and RF) should be considered.

– ELF magnetic fields may originate from, e.g. 12 V transformers, transformer stations, net currents on the electric wiring, water pipes, and other conduc-tive materials, infrared heaters, heating blankets and different types of power lines.

– ELF electric fields may originate from, e.g. electrical wiring, lamps, and appliances.

– VLF magnetic fields (”dirty power”) and/or VLF electric fields (“dirty electricity”) may be emitted from electronic

Electromagnetic spectrumNatural and artificial sources

1 Hz100

10 Hz101

100 Hz102

1 kHz103

10 kHz104

100 kHz105

1 MHz106

10 MHz107

100 MHz108

1 GHz109

10 GHz1010

100 GHz1011

1 THz1012

100 THz1014

10 THz1013

1 PHz1015

10 PHz1016

100 PHz1017

1 EHz1018

10 EHz1019

100 EHz1020

1 ZHz1021

10 ZHz1022

0 Hz

Electromagnetic fields and radiation Ionizing radiationOptical radiation

ELF RF / MW RadiationVLF

Earth

’s m

agne

tic fie

ld

Alpha,

bet

a, a

nd

gam

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radia

tion

Direct

electr

ic cu

rrent

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he E

arth

Figure 3: Examples of natural (green) and artificial (red and blue) EMF sources along the electromagnetic spectrum (256).


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devices like energy-efficient lighting, electronic trans-formers, induction cooker, variable speed frequency drives, light dimmer switches, power line communi-cation (PLC) connected to the electrical grid. These devices use current and/or voltage in short pulses that might produce harmonics and VLF transients on the electrical circuits, earthed materials and the ground.

– Typical RF radiation sources include, e.g. cordless phones (DECT), wireless Internet access (Wi-Fi), mobile phones and their base stations, radio and TV broadcast antennas, radar (military, airport, marine, and weather), Bluetooth, and the microwave ovens.

In the sleeping area, the most important exposure point is the head and trunk region followed by all other points with chronic or high exposure.

EMF measurements should be planned and carried out by specially trained and experienced testing special-ists and always in accordance with relevant standards, e.g. the VDB Guidelines of the German Association of Building Biology Professionals (257). In addition to the measure-ment results, the measurement report should also include suggestions on how to possibly reduce the EMF exposure.

To clarify certain issues, personal dosimeters with a data logging function are available to measure ELF mag-netic fields and radio-frequency radiation.

After the measurements have been commissioned by the person and carried out, the results should be dis-cussed with a physician familiar with the EMF issue.

EMF guidance valuesIn each case, the following aspects should be individually taken into account when evaluating EMF measurement results (27, 26):

– A person’s individual susceptibility, which, e.g. may be based on previous history of trauma (electrical, chemical, biological and physical).

– A person’s individual total body burden (e.g. expo-sure to noise, chemicals like neurotoxins)

– Duration of EMF exposure – EMF exposure during the night and day – Multiple exposure to different EMF sources – Signal intensity: watt/m2 (W/m2), volt/m (V/m),

ampere/m (A/m) – Signal characteristics were taken into account in the

EMF guidance values – see Supplement 3 (258) – Frequency – Risetime (∆T) of bursts, transients, etc. – Frequency and periodicity of bursts, e.g. cer-

tain GSM base stations (8.3 Hz), Wi-Fi networks (10 Hz), DECT cordless phones (100 Hz)

– Type of modulation (frequency modulation, amplitude modulation, phase modulation)

Regardless of the ICNIRP recommendations for specific acute effects, the following guidance values (Tables 1–3, 5 and 6) apply to sensitive locations with long-term expo-sure of more than 20 h per week (259). They are based on epidemiological studies (9, 10, 27, 221, 260–262), empirical observations, and measurements relevant in practice (258, 263), as well as recommendations by the Seletun State-ment (40) and the Parliamentary Assembly of the Council of Europe (42). The proposed guidance values are based on scientific data including a preventive component and aim to help restore health and well-being in already compromised patients. All levels provided are for incident intensities and whole-body exposure.

ELF magnetic fields (extremely low frequency) (ELF MF)Measurement specifications

Frequency range: 50/60 Hz mains electricity, up to 2 kHz. 16.7 Hz railroad systems in Austria, Germany, Switzerland, Sweden, and Norway, 400 Hz on airplanesType of measurement: Magnetic induction or flux density [T; mT; µT; nT]Field probe: Isotropic magnetic field probe (three orthogonal axes)Detector mode: RMS (root mean square) Measurement volume: Bed: Short-term measurements across entire sleeping area. Workplace: Short-term measurements across entire work area (e.g. sitting position). Long-term measurements: e.g. point close to the head/trunk in bed or at workplaceMeasurement period: Short-term measurements to identify field sources. Long-term measurements during sleep and work shiftBasis for evaluation: Long-term measurements: maximum (MAX) and arithmetic mean (AVG)

Precautionary guidance valuesIn areas where people spend extended periods of time ( > 4 h per day), minimize exposure to ELF magnetic fields to levels as low as possible or below the precautionary guidance values specified below.

Table 1: Precautionary guidance values for ELF magnetic fields.

ELF magnetic field

Daytime exposure

Nighttime exposure

Sensitive populations

Arithmetic mean (AVG)

100 nT (1 mG)1),2),3)

100 nT (1 mG)1),2),3)

30 nT (0.3 mG)5)

Maximum (MAX)

1000 nT (10 mG)2),4)

1000 nT (10 mG)2),4)

300 nT (3 mG)5)

Based on: 1)BioInitiative (9, 10); 2)Oberfeld (262); 3)Seletun Statement (40), 4)NISV (264); 5)Precautionary approach by a factor of 3 (field strength). See also IARC 2002 (30), Blank and Goodman (17), and TCO Development (265).


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Evaluation guidelines specifically for sleeping areasHigher frequencies than the mains electricity at 50/60 Hz and distinct harmonics should be evaluated more criti-cally. See also the precautionary guidance values for the VLF frequency range further below. If applicable, mains current (50/60 Hz) and traction current (16.7 Hz) should be assessed separately but added (squared average). Long-term measurements should be carried out especially at nighttime, but at least for 24 h.

ELF electric fields (extremely low frequency) (ELF EF)Measurement specifications

Frequency range: 50/60 Hz mains electricity, up to 2 kHz.16.7 Hz railroad systems in Austria, Germany, Switzerland, Sweden, and NorwayType of measurement: Electric field [V/m] without ground reference (potential-free)Field probe: Isotropic electric field probe (three orthogonal axes)Detector mode: RMS (root mean square) Measurement volume: Bed: Nine points across sleeping area. Workplace: Across entire work area (e.g. sitting position three or six points)Measurement period: Spot measurements to assess the exposure as well as to identify field sources. Since electric field exposure levels in the ELF frequency range usually do not change, long-term measurements are not needed.Basis for evaluation: Spot measurements (maximum) at relevant points of exposure

Precautionary guidance valuesIn areas where people spend extended periods of time ( > 4 h per day), minimize exposure to ELF electric fields to levels as low as possible or below the precautionary guid-ance values specified below.

Table 2: Precautionary guidance values for ELF electric fields.

ELF electric field Daytime exposure

Nighttime exposure


Maximum (MAX) 10 V/m1), 2) 1 V/m2) 0.3 V/m3)

Based on: 1)NCRP Draft Recommendations on EMF Exposure Guidelines: Option 2, 1995 (261); 2)Oberfeld (262); 3) Precautionary approach by a factor of 3 (field strength). See also TCO Development (265).

Evaluation guidelines specifically for sleeping areasHigher frequencies than the mains electricity at 50/60 Hz and distinct harmonics should be evaluated more critically. See also the precautionary guidance values for the VLF fre-quency range further below.

Radio-frequency radiation (RF)Measurement specifications

Frequency range: Radio and TV broadcast antennas, mobile phone base stations, e.g. TETRA (400 MHz),GSM (900 and 1800 MHz), UMTS (2100 MHz),LTE (800, 900, 1800, 2500–2700 MHz), cordless phone base stations, e.g. DECT (1900), Wi-Fi access points and clients (2450 and 5600 MHz), WiMAX (3400–3600 MHz). Above frequencies in MHz refer to European networks.Type of measurement: Usually electric field [V/m] - > calculated power density [W/m2; mW/m2; µW/m2]; for conversion units see Table 4.Field probe: Isotropic, biconical or logarithmic-periodic antennasDetector mode: Peak detector with max holdMeasurement volume: Point of exposure across bed and workplaceMeasurement period: Usually short-term measurements to identify RF field sources (e.g. acoustic analysis) and peak readingsBasis for evaluation: Band-specific or frequency-specific spot measurements (peak detector with max hold) of common signals at relevant points of exposure (e.g. with spectrum analyzer or at least band-specific RF meter)

Precautionary guidance values for selected RF sourcesIn areas where people spend extended periods of time ( > 4 h per day), minimize exposure to radio-frequency radiation to levels as low as possible or below the precautionary guid-ance values specified below. Frequencies to be measured should be adapted to each individual case. The specific guidance values take the signal characteristics of risetime (∆T) and periodic ELF “pulsing” into account (258). Note: Rectangular signals show short risetimes and consist of a broad spectrum of frequencies. The current density induced in the human body increases with increasing frequency in an approximately linear relationship (266).

Table 3: Precautionary guidance values for radio-frequency radiation.

RF source Max Peak/Peak Hold

Daytime exposure

Nighttime exposure

Sensitive populations1)

Radio broadcast (FM) 10,000 µW/m2 1000 µW/m2 100 µW/m2

TETRA 1000 µW/m2 100 µW/m2 10 µW/m2

DVBT 1000 µW/m2 100 µW/m2 10 µW/m2

GSM (2G) 900/1800 MHz

100 µW/m2 10 µW/m2 1 µW/m2

DECT (cordless phone) 100 µW/m2 10 µW/m2 1 µW/m2

UMTS (3G) 100 µW/m2 10 µW/m2 1 µW/m2

LTE (4G) 100 µW/m2 10 µW/m2 1 µW/m2

GPRS (2.5G) with PTCCH* (8.33 Hz pulsing)

10 µW/m2 1 µW/m2 0.1 µW/m2

DAB+ (10.4 Hz pulsing) 10 µW/m2 1 µW/m2 0.1 µW/m2

Wi-Fi 2.4/5.6 GHz (10 Hz pulsing)

10 µW/m2 1 µW/m2 0.1 µW/m2

*PTCCH, packet timing advance control channel.Based on: BioInitiative (9, 10); Kundi and Hutter (260); Leitfaden Senderbau (221); PACE (42); Seletun Statement (40). 1)Precaution-ary approach by a factor of 3 (field strength) = a factor of 10 (power density). See also IARC 2013 (24) and Margaritis et al. (267).


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Table 4: Conversion of radio-frequency radiation measurement units.

Conversion of RF Measurement units

mW/m2 10 1 0.1 0.01 0.001 0.0001 µW/m2 10,000 1000 100 10 1 0.1 µW/cm2 1 0.1 0.01 0.001 0.0001 0.00001 V/m 1.9 0.6 0.19 0.06 0.019 0.006

Magnetic fields in the VLF range (VLF MF)Measurement specifications

Frequency range: 3 kHz–3 MHz. Frequency-specific measurements (spectrum analyzer/EMF meter), e.g. “dirty power”, powerline communication (PLC), radio-frequency identification transmitters (RFID), compact fluorescent lamps (CFL)Type of measurement: Magnetic field [A/m] – > calculated magnetic induction [T; mT; µT; nT]Field probe: Isotropic or anisotropic magnetic field probeDetector mode: RMS (root mean square) Measurement volume: Point of exposure across bed and workplaceMeasurement period: Short-term measurements to identify field sources. Long-term measurements during sleep and work shiftBasis for evaluation: Long-term measurements: RMS detector, arithmetic mean and maximum at relevant points of exposureNote: If an elevated exposure is detected, power quality analyzers and oscilloscopes can be used on the actual wiring to trace the source of the dirty power.

Precautionary guidance valuesIn areas where people spend extended periods of time ( > 4 h per day), minimize exposure to VLF magnetic fields to levels as low as possible or below the precautionary guidance values specified below.

Table 5: Precautionary guidance values for VLF magnetic fields.

VLF magnetic field

Daytime exposure

Nighttime exposure


Arithmetic mean (AVG)

1 nT (0.01 mG)1)

1 nT (0.01 mG)1) 0.3 nT (0.003 mG)2)

Maximum (MAX)

10 nT (0.1 mG)1)

10 nT (0.1 mG)1) 3 nT (0.03 mG)2)

Based on: 1)The current density induced in the human body increases with increasing frequency in an approximately linear relationship (266). Therefore, the guidance value of the magnetic field in the VLF frequency range should be lower than the one of the 50/60 Hz magnetic field, e.g. for 100 nT RMS/100 = 1 nT. For the rationale of 100 nT (avg) and 1 µT (max), see section ELF magnetic fields. 2)Precautionary approach by a factor of 3 (field strength). See also TCO Development (265).

Electric fields in the VLF range (VLF EF)Measurement specifications

Frequency range: 3 kHz–3 MHz. Frequency-specific measurements (spectrum analyzer/EMF meter), e.g. ”dirty electricity”, powerline communication (PLC), radio-frequency identification transmitters (RFID), compact fluorescent lamps (CFL)Type of measurement: Electric field [V/m]Field probe: Isotropic, biconical, logarithmic-periodic electric field probeDetector mode: RMS arithmetic meanMeasurement volume: Point of exposure across bed and workplaceMeasurement period: Short-term measurements to identify field sources. Long-term measurements during sleep and work shiftBasis for evaluation: Long-term measurements: arithmetic mean at relevant points of exposureNote: If an elevated exposure is detected, power quality analyzers and oscilloscopes can be used on the actual wiring to trace the source of the dirty power.

Precautionary guidance valuesIn areas where people spend extended periods of time ( > 4 h per day), minimize exposure to VLF electric fields to levels as low as possible or below the precautionary guid-ance values specified below.Table 6: Precautionary guidance values for VLF electric fields.

VLF electric field Daytime exposure

Nighttime exposure


Arithmetic mean (AVG) 0.1 V/m1) 0.01 V/m1) 0.003 V/m2)

Based on: 1)The current density induced in the human body increases with increasing frequency in an approximately linear relationship (266). Therefore, the guidance value of the electric field in the VLF frequency range should be lower than the one of the 50/60 Hz elec-tric field, e.g. for 10 V/m/100 = 0.1 V/m. For the rationale of 10 V/m and 1 V/m, see section ELF electric fields. 2)Precautionary approach by a factor of 3 (field strength). See also TCO Development (265).

Reduction and prevention of EMF exposure

Preventing or reducing EMF exposure after consulting a testing specialist is advantageous for several reasons:(a) To prevent and reduce risks to individual and public

health,(b) To identify any links to health problems,(c) To causally treat the EMF-related health problems.

There are numerous potential causes of relevant EMF expo-sures, and this EMF guideline can only give a few examples. Further information can be found, for instance, in the docu-ment “Options to Minimize EMF/ RF/Static Field Exposures in Office Environments” (268) and “Elektrosmog im Alltag”


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(269). For detailed information on physics, properties, and measurement of EMF, see Virnich (270); regarding reduc-tion of radio-frequency radiation (RF) in homes and offices, see Pauli and Moldan (271).

In most cases, it will be necessary to consult an expert (e.g. qualified EMF/RF engineer/ consultant) and/or elec-trician who will advise the person on what measures could be taken to reduce EMF exposure.

EMF exposure reduction – first stepsAs a first step, recommendations are given (also as preven-tive measures) to eliminate or reduce typical EMF expo-sures, which may help alleviate health problems within days or weeks. The following actions may be suggested:

Preventing exposure to radio-frequency radiation (RF) – Keep mobile phone/smartphone and cordless phone

calls short; use the speakerphone function or a hands-free kit.

– Avoid wearing the mobile phone/smartphone close to the body.

– Deactivate all non-essential wireless mobile phone apps, which cause periodic radiation exposure.

– Keep mobile phones/smartphones in “airplane mode” whenever possible or deactivate mobile data, Wi-Fi, Bluetooth and near field communication (NFC) in the smartphone settings.

– Disconnect (unplug) the power supply of all DECT cordless phone base stations. So called “ECO Mode” or “zero-emission” DECT phones are only condition-ally recommended because the exposure by the hand-set is still present. A “traditional” corded phone is recommended instead.

– Disconnect (unplug) the power supply to all Wi-Fi access points or Wi-Fi routers. Many LAN routers now come equipped with additional Wi-Fi. Call the provider of the LAN router and ask to have the Wi-Fi deactivated. It is usually also possible to do so online by following the provider’s instructions.

– In case of external RF radiation sources, rooms – especially bedrooms – facing away from the source should be chosen.

– Avoid powerline communication for Internet access (dLAN) and instead use a hardwired Ethernet cable (LAN).

– Avoid exposure to RF radiation (e.g. wireless devices like, home entertainment, headsets, baby monitors, computer games, printers, keyboards, mouse, home surveillance systems) at home, in offices, and in cars.

– Avoid exposure to energy-efficient lighting (compact fluorescent lamps as well as some LEDs generate high frequency transients). These types of lamps can be replaced with incandescent or line-voltage halogen incandescent lamps until good-quality lighting energy-efficient lamps become commercially available.

Preventing exposure to ELF electric and magnetic fields – Move the bed or desk away from the wiring in the

walls and power cords. A minimum distance of 30 cm (1 ft) from the wall is recommended.

– As magnetic fields can pass through walls, make cer-tain that there are no magnetic sources immediately beneath or above a bed or in an adjacent room.

– Another simple complementary action is to discon-nect the power supply to the bedroom (turn off cir-cuit breaker or fuse) for the nighttime while sleeping; try it for a test phase of, e.g. 2 weeks. In general, this measure is not always successful because circuits of adjacent rooms contribute to the electric field lev-els. ELF electric field measurements are required to know exactly which circuit breakers need to be dis-connected. The benefits should be weighed against the potential risk of accidents; therefore, the use of a flashlight for the test phase should be recommended.

– Disconnect the power supply to all non-essential elec-tric circuits, possibly in the entire apartment or house. (N.B. See note above.)

– Avoid using an electric blanket during sleep; not only turn it off, but also disconnect it.

– Avoid extended exposures close to running electric motors. As a first step, keep a minimum distance of 1.5 m (5 ft). As a second step, establish a safe distance based on magnetic field measurements.

Preventing exposure to static magnetic/static electric fields

– Sleep in a bed and mattress without metal. – Avoid sleeping close to iron materials (radiator,

steel, etc.) – Wearing synthetic clothing and, e.g. rubber-soled

shoes and not regularly being in contact with the earth can result in build up of static electricity. Cotton clothing and leather-soled shoes will help avoid static electricity.

EMF exposure reduction – second stepsAs a second step, EMF measurements and mitigation measures should be carried out. Typical examples are:


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– Measure the ELF electric field in the bed. Based on the measurement results, install automatic demand switches in those circuits that increase the exposure.

– Measure the ELF electric field at all other places that are used for extended periods at home and at work. If necessary, choose lamps used close to the body with a shielded electric cable and a grounded lamp fixture (metal). Especially in lightweight construction (wood, gypsum board), electrical wiring without ground-ing (two-slot outlets) might have to be replaced with grounded electrical wiring or shielded electrical wir-ing. In special cases, shielded wiring and shielded outlets may have to be installed in the whole building.

– Measure the ELF magnetic field close to the bed, e.g. for 24 h. If net currents are detected, the electrical wir-ing and grounding system of the building must be cor-rected to reduce the magnetic fields.

– Install a residual current device (RCD) or ground-fault circuit interrupter (GFCI) to prevent electric shocks (safety measure).

– Measure radio-frequency radiation and mitigate high exposure levels by installing certain RF shielding mate-rials for the affected walls, windows, doors, ceilings, and floors. For example, in a multiunit setting (condo-miniums or highrise apartments, townhomes), proxim-ity to neighbors can contribute to inhome exposure.

– Measure dirty electricity/dirty power (electric and magnetic fields in the VLF frequency range) and iden-tify the sources in order to remove them. If this is not possible, appropriate power filters in line with the source may be used.

Diagnosis

We will have to distinguish between EHS and other EMF-related health problems like certain cancers, Alzheimer’s, ALS, male infertility, etc. that might have been induced, promoted, or aggravated by EMF exposure. An investi-gation of EHS and other EMF-related health problems will largely be based on a comprehensive case history, focusing, in particular, on correlations between health problems and times, places, and circumstances of EMF exposure, as well as the progression of symptoms over time and the individual susceptibility. In addition, meas-urements of EMF exposure and the results of additional diagnostic tests (laboratory tests, cardiovascular system) serve to support the diagnosis. Moreover, all other poten-tial causes should be excluded as far as possible.

In 2000 the Nordic Council of Ministers (Finland, Sweden, and Norway) adopted the following unspecific

ICD-10 code for EHS: Chapter XVIII, Symptoms, signs and abnormal clinical and laboratory findings, not elsewhere classified, code R68.8 “Other specified general symptoms and signs” (Nordic ICD-10 Adaptation, 2000) (272).

Regarding the current International Classification of Diseases (ICD), ICD-10-WHO 2015, we recommend at the moment:(a) Electromagnetic hypersensitivity (EHS): to use the

existing diagnostic codes for the different symptoms plus code R68.8 “Other specified general symptoms and signs” plus code Z58.4 “Exposure to radiation” and/or Z57.1 “Occupational exposure to radiation.”

(b) EMF-related health problems (except EHS): to use the existing diagnostic codes for the different diseases/symptoms plus code Z58.4 “Exposure to radiation” and/or Z57.1 “Occupational exposure to radiation.”

Regarding the next ICD update to be published in 2018 (ICD-11 WHO), we recommend:(a) To create ICD codes for all environmentally induced

chronic multisystem illnesses (CMI) like multiple chemical sensitivity (MCS), chronic fatigue syndrome (CFS), fibromyalgia (FM), and electromagnetic hyper-sensitivity (EHS) on the basis of their clinical and pathological description (204, 207).

(b) To expand chapter XIX, Injury, Poisoning and Certain Other Consequences of External Causes (T66-T78), to include/distinguish effects of EMF (static magnetic field, static electric field, ELF magnetic field, ELF electric field, VLF magnetic field, VLF electric field, radio-frequency radiation), infrared radiation, visible light, UV radiation and ionizing radiation.

(c) To expand chapter XXI, Factors Influencing Health Status and Contact with Health Services (Z00-Z99), to include/distinguish factors as EMF (static magnetic field, static electric field, ELF magnetic field, ELF electric field, VLF magnetic field, VLF electric field, radio-frequency radiation), infrared radiation, visible light, UV radiation, and ionizing radiation.

Treatment of the patient including the environment

The primary method of treatment should mainly focus on the prevention or reduction of EMF exposure that is reduc-ing or eliminating all sources of EMF at home and in the workplace. The reduction of EMF exposure should also be extended to schools, hospitals, public transport, public places like libraries, etc. in order to enable EHS persons an unhindered use (accessibility measure). Many exam-ples have shown that such measures can prove effective.


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With respect to total body load of other environmental influences, they must also be regarded.

Beside EMF reduction, other measures can and must be considered. These include a balanced homeostasis in order to increase the “resistance” to EMF. There is increasing evidence that a main effect of EMF on humans is the reduction of their oxidative and nitrosative regu-lation capacity. This hypothesis also explains observa-tions of changing EMF sensitivity and the large number of symptoms reported in the context of EMF exposure. Based on currently available knowledge it appears useful to recommend a treatment approach, as those gaining ground for multisystem illnesses, that aims at minimiz-ing adverse peroxynitrite effects. Measures that enhance the immune system and reduce stress in combination with detoxification will promote EHS recovery.

It should be stressed, that psychotherapy has the same significance as in other diseases. Products that are offered in the form of plaques and the like to “neutralize” or “harmonize” electrosmog should be evaluated with great restraint. Psychological stress generated by a lack of understanding or support by family, friends and physi-cians can exacerbate the symptoms of EHS as can stressing about exposure. For rapid recovery, the treatments need to apply to the body, mind and spirit of the individual.

In summary, the following treatment and accessibility measures appear advantageous, depending on the indi-vidual case:

Reduction of EMF exposureThis should include all types of EMF exposures relevant to the person, especially during sleep and at work – see Chapter “Reduction of EMF Exposure”. For more informa-tion, see e.g. “Options to Minimize EMF/RF/Static Field Exposures in Office Environment” (268) and “Elektrosmog im Alltag” (269).

Environmental medicine treatmentsUntil now, no specific treatment of EHS has been estab-lished. The following paragraphs are recommendations based on the combined experience of the team. They can be considered either as an attempt to restore the full regu-lative capacity of the patients, as general advice for healthy living (that could and should be adapted to the cultural and individual situation of the patient), or as a more tar-geted approach to address the specific problems of EHS individuals according to the experience of the team.

Controlled clinical trials would be necessary to assess optimal treatment and accessibility measures. Actual data indicate that the functional deficits, which can be

found in patients with EHS, correspond to those we can find in CMI such as MCS, CFS, and FM. The target of the therapy is the regulation of the physiological dysfunction detected by diagnostic steps (see chapter 2 “Examination and Findings”). The main therapeutic target includes both general and adjuvant procedures and specific treatments. The latter are challenging and need special knowledge and experience in clinical environmental medicine treat-ments. Main therapeutic targets include:

– Control of total body burdenBesides the reduction of EMF exposure, the reduction of the total body burden by various environmental pollutants (home, workplace, school, hobby), food additives, and dental materials is indicated.

– Reduction of oxidative and/or nitrosative stressReactive oxygen species (ROS) and reactive nitrogen species (RNS) are free radicals naturally produced in cells. Scavengers guarantee the balance between the production of free radicals and the rate of their removal. Many biologically important compounds with antioxidant (AO) function have been identified as endogenous and exogenous scavengers. Among the endogenous AO, we distinguish between enzymatic AO (catalase, glutathione peroxidase, glutathione reductase, superoxide dismutase) and non-enzymatic AO [bilirubin, ferritin, melatonin, glutathione, metal-lothionin, N-acetyl cysteine (NAC), NADH, NADPH, thioredoxin, 1,4,-bezoquinine, ubiquinone, uric acid]. They interact with exogenous dietary and/or synthetic AO (carotenoids, retinoids, flavonoids, polyphenols, glutathione, ascorbic acid, tocopherols). The complex regulation and use of these substances is the thera-peutic challenge (232, 273).

– Regulation of intestinal dysfunctionEndogenous and exogenous scavengers act synergis-tically to maintain the redox homeostasis. Therefore, dietary or natural antioxidants play an important role to stabilize this interaction.Treatment of a leaky gut, food intolerance, and food allergy is a prerequisite for maintaining redox homeo-stasis (274) and also requires special knowledge and experience.

– Optimizing nutritionBioactive food is the main source of antioxidant com-ponents such as vitamin C, vitamin E, NAC, carote-noids, CoQ10, alpha-lipoic acid, lycopene, selenium, and flavonoids (275, 276). For instance, the regenera-tion of vitamin E by glutathione or vitamin C is needed to prevent lipid peroxidation. The dietary antioxi-dants only can have beneficial effects on the redox system if they are present in sufficient concentration


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levels (273). Alpha-lipoic acid acts directly and indi-rectly as a scavenger of free radicals including, singlet oxygen, superoxide, peroxyl radicals, and the breakdown radicals of peroxynitrite (232). It has been shown that the number of free electrons in micronu-trients determines how effective they are. In organic food, the number of free electrons is higher than in conventionally produced food (277). Especially in the case of food intolerances, the tailored substitu-tion of micronutrients in the form of supplements is necessary.

– Control of (silent) inflammationElevated nitric oxide levels and the reaction with superoxide always leads to elevated peroxynitrate levels, which induce ROS levels as no other substance does (NO/ONOO− cycle). As a result, the nuclear factor κB (NF-κB) is activated, inducing inflammatory cytokines such as tumor necrosis factor α (TNF-α), interleukin-1β (IL-1β), interleukin-6 (IL-6), interleu-kin-8 (IL-8), and interferon gamma (IFN-γ) and acti-vating various NO synthases (232). Tocopherols (278, 279), carotenoids at low concentration levels (280), vitamin C (281, 282), NAC (283), curcumin (284), res-veratrol (285, 286), flavonoids (287) have shown to interrupt this inflammatory cascade at various points.

– Normalization of mitochondrial functionMitochondrial function may be disturbed in two ways. First: the high amount of free radicals may block pro-duction of adenosine triphosphate (ATP), leading to muscle pain and fatigue. Second: in the case of silent (smoldering) inflammation, the demand for more energy is elevated by 25% (236), causing a high con-sumption of ATP. In this case, NADH, L-carnitine, and CoQ10 are essential for ATP synthesis.Due to the lack of ATP, the stress regulation of catecho-lamines especially norepinephrine (NE) is reduced because catabolism of NE by S-adenosylmethionine is ATP dependent (288–290). Furthermore, stress regu-lation has a high demand for folate, vitamin B6, and methylcobalamine. Genetic polymorphisms of COMT and MTHFR influence the individual need for those substances (244, 291).

– DetoxificationIn humans, the accumulation of environmental toxins has an individual profile of many different inorganic and organic chemicals, which make up the total body load (292).Among the inorganic substances, metals and their salts play the dominant role and might be of impor-tance to patients with EHS. Elemental mercury (Hg°) and other heavy metals such as lead (Pb) accumulate

in the brain (293), especially at chronic low dose exposure. They may have toxic effects and can induce various immune reactions (294, 295). Whereas no specific active substance generally exists for the detoxification of chemicals, there are two groups of substances with more specific effects that can be used for the detoxification of metals.1. Substances with nonspecific physiological

effects: glutathione, NAC, alpha-lipoic acid, vita-min C, and selenium.

2. Chelating agents for detoxification of metals (296–298): the most important chelating agents are sodium thiosulfate 10%, DMPS (2,3-dimer-capto-1-propanesulfonic acid), DMSA (meso- dimercaptosuccinic acid), and EDTA (2,22,23,232- ethane-1,2-diyldinitrotetraacetic acid).

It should be noted that these substances should be used only by those designated as experts in this par-ticular field.

– Adjuvant therapies1. Drinking water For detoxification reasons, a higher intake of high-quality drinking water with low mineral content and no CO2 is needed. The intake quantity should range from 2.5 to 3.0 L (10–12 8-oz glasses) daily.

2. Light Most of the people in central and northern Europe are depleted of vitamin D. Sufficient natural daylight exposure during the vitamin D-producing months (spring to fall) is one important factor. At the same time, prevention of actinic damage to the skin is nec-essary. In addition to natural sunlight, light therapy and low level lasers can promote healing, reduce inflammation, promote circulation, and enhance cel-lular ATP production.

3. SaunaSauna and therapeutic hyperthermia is an adjuvant therapy for the detoxification of almost all xenobi-otics. These therapies have to be carefully used. An interaction with detoxifying drugs takes place. Sauna helps to regenerate tetrahydrobiopterin from dihyd-robiopterin, which is essential for the metabolism of catecholamines and serotonin (299). However, not all saunas are alike. Traditional saunas or infrared saunas with low electric and low magnetic fields that do not use toxic glues and chemically treated wood are recommended.


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4. OxygenA part of patients with EHS suffer from mitochondrial dysfunction. Sufficient natural oxygen is helpful. As both hypoxia and hyperbaric oxygen can produce oxi-dative stress, hyperbaric oxygen therapy should only be performed if the patients are treated with sufficient antioxidants at the same time.

5. ExerciseThe optimal amount of exercise is still being debated. A person’s physical capacity should be assessed by ergometry in order to prescribe an individual exercise regime. Environmental medicine experience indicates that for sick people only low-impact aerobic exercise should be used. In general, start with a workload of 20–30 watts that often can be finished at 60–70 watts. Exercise on an ergometer allows better control of the consumption of energy compared to walking or running. No fatigue should result from exercising, at least after half an hour.

6. SleepSleep problems are very common in patients with EHS. Sleep disturbance is associated with a reduced melatonin level. In the case of chronic inflammation, the activation of IDO (indolamine-2,3-dioxygenase) reduces the production of serotonin and, in turn, it also reduces melatonin levels. EMF exposure might block the parasympathetic activity while sympathetic activity persists. Concerning sleep disturbances, any therapy has to follow the pathogenic causes. Optimal sleep is necessary to save energy and to regulate the functions of the immune and neuroendocrine systems.

7. Protection from blue lightWavelengths of visible light below 500 nm are called “blue light”. Low doses of blue light can increase feel-ings of well-being, but larger amounts can be harmful to the eyes. In natural daylight, the harmful effects of “blue light” are balanced out by the regenerative effect of the red and infrared content. The escalating use of electronic light sources – such as fluorescent tubes and compact fluorescent lamps (CFL), computer screens, laptops, tablets, smartphones, and certain LED bulbs – has increased our exposure to “blue light”, which at this level is suspected of playing a role in the development of age-related macular degen-eration and circadian misalignment via melatonin suppression, which is associated with an increased risk of sleep disturbance, obesity, diabetes mellitus,

depression, ischemic heart disease, stroke, and cancer. Extended exposure to artificial “blue light” in the evening should therefore be limited. Antioxi-dants, especially melatonin (300, 301), and blue light screen filters (302–304) could be helpful.

8. Exposure to the natural electromagnetic fields of the Earth.

Most people in urban centers are disconnected from the Earth’s natural grounding/magnetic fields by walking with rubber-soled shoes, wearing synthetic clothing, driving in metal boxes with rubber wheels, and living and working in concrete buildings that are permeated with artificial electromagnetic fields and radiation. Spending time in the woods, walking bare-foot along a beach, lying on the grass, sitting on rocks, or strolling outside after a rain shower help ground a person and help balance the often enhanced posi-tively charged ions that are associated with ill health.

Dental medicineDental medicine still works with toxic or immunoreactive materials, e.g. mercury, lead oxide, gold, and titanium. Environmental dental medicine demands that these mate-rials not be used (305–308). The removal of toxic dental materials must take place under maximum safety condi-tions (avoid inhalation!). The elimination of particularly heavy metals from the body might be indicated. In general terms, endoprosthetic materials should be inert with respect to immunoreactivity. Based on our current knowl-edge, zirconium dioxide seems to be a neutral material. However, mechanical abrasion of the coated surface by the dentist should be avoided.

Immunotoxic metals show a similar pathophysiology with respect to oxidative stress, mitochondriopathy, and inflammation.

Lifestyle coachingLifestyle coaching may include balanced exercise, nutri-tion, reduction of addictive substances, change of sleep habits, etc. and stress reduction measures (reduction of general stress and work stress), as well as methods to increase stress resistance via, e.g. autogenic training, yoga, progressive muscle relaxation, breathing tech-niques, meditation, tai chi, and qigong.

Treatment of symptomsA well-balanced treatment of symptoms is justified until the causes have been identified and eliminated. However,


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it is of paramount importance to realize that the reduction of symptoms may put the person at risk for an increased environmental EMF load, thus generating possible future, long-term health effects, including neurological damage and cancer. The treating physician faces a very diffi-cult ethical task when doing so, and the associated risks must be pointed out – in an equally well-balanced way – to the patient in question. From an ethical perspective, treating the symptoms is, of course, a very good start to provide immediate relief, but – without a concurrent envi-ronmental exposure reduction and lifestyle coaching – it may prove counter-productive in the long run. For a con-ventionally trained physician, this might seem a very new way of reasoning, but it is the only way to successfully and effectively alleviate symptoms and to achieve complete clinical recovery when dealing with chronic multisystem illnesses (CMI) and EHS. Though even if the causes are not known at the outset, it is already important at this stage to provide advice on how to reduce a person’s exposure to electromagnetic fields and other environmental stressors to prevent further damage and promote healing.

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Supplemental Material: The online version of this article (DOI: 10.1515/reveh-2016-0011) offers supplementary material, available to authorized users.


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Guideline of the Austrian Medical Association for the diagnosis and treatment

of EMF-related health problems and illnesses (EMF Syndrome) (2011)

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Guideline of the Austrian Medical Association ( ) for the diagnosis and treatment of EMF-related health problems and illnesses (EMF syndrome)

Consensus paper of the Austrian Medical Association’s EMF Working Group ( AG-EMF)

Adopted at the meeting of environmental medicine officers of the Regional Medical Association´s and the Austrian Medical Association on 3rd March 2012 in Vienna.

Introduction

There has been a sharp rise in unspecific, often stress-associated health problems that increasingly present physicians with the challenge of complex differential diagnosis. A cause that has been accorded little attention so far is increasing electrosmog exposure at home, at work and during leisure activities, occurring in addition to chronic stress in personal and working life. It correlates with an overall situation of chronic stress that can lead to burnout.

How can physicians respond to this development?

The Austrian Medical Association has developed a guideline for differential diagnosis and potential treatment of unspecific stress-related health problems associated with electrosmog. Its core element is a patient questionnaire consisting of a general assessment of stress symptoms and a specific assessment of electrosmog exposure.

The guideline is intended as an aid in diagnosing and treating EMF-related health problems.

Background

Many people are increasingly exposed, to various degrees, to a combination of low and high frequency electric fields (EF), magnetic fields (MF) and electromagnetic fields (EMF) of different signal patterns, intensities and technical applications for varying periods of time, colloquially referred to as electrosmog. Physicians are often confronted with unspecific complaints without clearly identifiable causes (Huss and Röösli 2006). It has been suspected that environmental conditions such as increasing exposure of the population to radio waves, emanating e.g. from cordless phones, mobile phone base stations, cell phones, GPRS, UMTS, data cards for laptop and notebook computers and wireless LAN (WLAN), but also exposure to electric and magnetic fields emanating from power lines, devices and equipment, may play a causal role (Blake Levitt and Lai 2010). For the medical profession, this raises new challenges in diagnosis and treatment. A central issue for

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the causal attribution of symptoms is the assessment of variation in health problems depending on time and location, which is particularly relevant for environmental causes such as EMF exposure. Austria is currently rolling out the fourth generation of mobile telephony (LTE), as well as smart metering (for electricity, gas and water consumption), resulting in additional EMF exposure of the population. New radio technologies and applications have been introduced without certainty about their health effects, raising new challenges for medicine. For instance, the issues of so-called non-thermal effects and potential long-term effects of low-dose exposure were hardly investigated at all prior to introduction. Some patients suspect a link between EMF exposure and their health problems. Moreover, physicians are increasingly confronted with health problems with unidentified causes. Pursuing an evidence-based treatment strategy in this context is a challenge for differential diagnosis. In Austria, there are no democratically legitimized limits to protect the general population from EMF exposure. The recommendations of the WHO, compiled by the International Commission on Non-Ionizing Radiation Protection (ICNIRP 1998), are based on a thermal model. These recommendations were adopted by the EU in its Council Recommendation of 1999 (EU-Ratsempfehlung 1999) and by Austria in its pre-standard ÖVE/ÖNORM E 8850:2006 02 01 (ÖNORM 2006) without taking into account long-term non-thermal effects. In August 2007, the BioInitiative, an international group of experts, published a comprehensive report calling for preventive measures against EMF exposure based on the scientific evidence available (BioInitiative 2007). Consequently, the European Environment Agency compared electrosmog to other environmental hazards such as asbestos or benzene (EEA 2007). In April 2009, a resolution of the European Parliament called for a review of the EMF limits in the EU Council Recommendation of 1999, which was based on the guidelines of the ICNIRP, with reference to the BioInitiative Report (EU Parliament 2009). In May 2011, the Parliamentary Assembly of the Council of Europe adopted the report “The potential dangers of electromagnetic fields and their effect on the environment” (PACE 2011). The report calls for a number of measures to protect humans and the environment, especially from high-frequency electromagnetic fields. One of the recommendations is to “take all reasonable measures to reduce exposure to electromagnetic fields, especially to radio frequencies from mobile phones, and particularly the exposure to children and young people who seem to be most at risk from head tumours”. Also in May 2011, a group of experts at the International Agency for Research on Cancer, an agency of the WHO, classified radiofrequency electromagnetic fields as possibly carcinogenic (Group 2B) for humans (IARC 2011).

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A representative telephone survey (n=2048, age >14 years) carried out in 2004 in Switzerland yielded a frequency of 5% (95% CI 4-6%) for a self-attributed “diagnosis” of electrosensitivity (Schreier et al. 2006). In another survey carried out in Switzerland, in 2001, 394 respondents attributed specific health problems to EMF exposure. Among others, the following symptoms were reported as occurring frequently: sleep problems (58%), headaches (41%), nervousness (19%), fatigue (18%) and difficulty concentrating (16%). The respondents listed mobile phone base stations (74%), cell phones (36%), cordless phones (29%) and high-voltage lines (27%) as causes. Two thirds of respondents had taken measures to reduce their symptoms, the most frequent measure being to avoid exposure. Remarkably, only 13% had consulted their physicians (Röösli et al. 2004). While a 2006 study by Regel et al. described no exposure effects, two provocation studies on exposure of “electrosensitive” individuals and control subjects to mobile phone base station signals (GSM, UMTS or both) found a significant decline in well-being after UMTS exposure in the individuals reporting sensitivity (Zwamborn et al. 2003, Eltiti et al. 2007). Analysis of the data available on exposure of people living near mobile phone base stations has yielded clear indications of adverse health effects (Santini et al. 2002, Navarro et al. 2003, Hutter et al. 2006, Abdel-Rassoul et al. 2007, Blettner et al. 2008). Based on the scientific literature on interactions of EMF with biological systems, several mechanisms of interaction are possible. A plausible mechanism at the intracellular and intercellular level, for instance, is interaction via the formation of free radicals or oxidative and nitrosative stress (Friedmann et al. 2007, Simkó 2007, Pall 2007, Bedard and Krause 2007, Pacher et al. 2007, Desai et al. 2009). It centres on the increased formation of peroxynitrite (ONOO-) from a reaction of nitrogen monoxide (NO) with superoxide (O2-). Due to its relatively long half-life, peroxynitrite damages a large number of essential metabolic processes and cell components. This approach can serve as a plausible explanation of many of the health problems, symptoms and their progression observed in the context of EMF exposure. There are increasing indications that EMF syndrome (EMFS) should be counted among multi-system disorders (Pall 2007) such as Chronic Fatigue Syndrome (CFS), Multiple Chemical Sensitivity (MCS), fibromyalgia (FM) and Post Traumatic Stress Disorder (PTSD). In Sweden, EMF syndrome is designated as electrohypersensitivity (EHS), considered a physical impairment and recognized as a disability. With reference to UN Resolution 48/96, Annex, of 20 December 1993 (UN 1993), local governments grant support to individuals with EHS. Employees with EHS have a right to support from their employers so as to enable them to work despite this impairment. Some hospitals in Sweden provide rooms with low EMF exposure.

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The Austrian Medical Association considers it its duty and its mission to provide members of the medical profession with a compilation of the current state of the scientific and political debate from a medical perspective and with specific recommendations for action in this first guideline. The guideline can only be improved by suggestions, criticism and amendments. Due to the rapid development of various technologies, the recommendations need to be adapted on an ongoing basis. We therefore invite all medical professionals to send contributions to the next edition of the guideline to the following email address: [email protected]

What to keep in mind when dealing with patients and EMF

In the case of unspecific health problems (see patient questionnaire) for which no clearly identifiable cause can be found, EMF exposure should in principle be taken into consideration as a potential cause, especially if the patient suspects that it may be the cause.

How to proceed if EMF-related health problems are suspected

The recommended approach to diagnosis and treatment is intended as an aid and should, of course, be modified as each individual case requires.

1. History of health problems and EMF exposure 2. Examination and findings 3. Measurement of EMF exposure 4. Prevention or reduction of EMF exposure 5. Diagnosis 6. Treatment

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Fig. 1: Flow chart for diagnosing EMF-related health problems

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1. History of health problems and EMF exposure

A patient questionnaire to facilitate a systematic history of health problems and EMF exposure, compiled by the Austrian Medical Association’s EMF Working Group, is available for download at: www.aerztekammer.at/referate Umweltmedizin. The patient questionnaire consists of three sections:

a) List of symptoms b) Variation of health problems depending on time and location c) Assessment of EMF exposure

a) List of symptoms

The list of symptoms in the patient questionnaire serves to systematically quantify stress-related health problems regardless of their causes. It also includes questions on when the health problems first occurred. Most EMF-related symptoms fall within the scope of so-called stress-related health problems, e.g. sleep problems, fatigue, exhaustion, lack of energy, restlessness, heart palpitations, blood pressure problems, muscle and joint pain, headaches, depression, difficulty concentrating, forgetfulness, anxiety, urinary urgency, anomia, dizziness, tinnitus and sensations of pressure in the head and the ears. The health problems may range in severity from benign, temporary symptoms, such as slight headaches or paraesthesia in the head when using a cell phone, to severe, debilitating symptoms that drastically impair physical and mental health. b) Variation of health problems depending on time and location

The answers to questions on when and where the health problems occur or recede, and when and where the symptoms increase or are particularly evident, provide indications as to whether the health problems may be related to specific times and locations. They must be interpreted in the context of the patient’s living conditions and circumstances. c) Assessment of EMF exposure

Regardless of whether or not the patient suspects EMF exposure as a cause, these questions should be used to assess the kind of exposure that exists. It is important to note that only certain types of EMF exposure can be assessed by means of the questionnaire, such as use of cell phones and cordless phones. Detection of other types of EMF exposure, e.g. due to high frequency transmitter sites or the electric or magnetic fields of power lines, generally requires measurements (see section 3: Measurement of EMF exposure). In principle, questions should be asked to assess EMF exposure at home and at work, keeping in mind that the degree of EMF exposure may vary at different times.

2. Examination and findings

There are no findings specific to EMF, which makes diagnosis and differential diagnosis a considerable challenge. A method that has proven useful is to use stress-

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associated findings for diagnosis and follow-up and to evaluate them synoptically. Basic diagnostic tests should be carried out as a first step, followed by measurements of EMF exposure as a second step. Only then can specific diagnostic tests be considered.

Cardiovascular system

Basic diagnostic tests

� Blood pressure and heart rate (in all cases resting heart rate in the morning while still in bed), including self-monitoring, possibly several times a day, e.g. at different places and with journaling of subjective well-being for a week.

Specific diagnostic tests

� 24-hour blood pressure monitoring (absence of night-time decline) � 24-hour ECG (heart rhythm diagnosis) � 24-hour heart rate variability HRV (autonomous nervous system diagnosis)

Laboratory tests

Basic diagnostic tests

� Early morning urine

� Adrenaline � Noradrenaline � Noradrenaline/adrenaline quotient � Dopamine � Serotonin

� Early morning urine

� 6-OH melatonin sulphate

� Saliva

� Cortisol (8 am, 12 am and 8 pm)

� Blood

� Blood count and differential blood count � Fasting blood glucose and postprandial blood glucose � HBA1c � TSH

Additional diagnostic tests – specific individual parameters depending on symptoms

� Late morning urine

� Histamine, glycine � Gamma-aminobutyric acid GABA � Glutamate

� Saliva

� Alpha amylase A (10 am) � Dehydroepiandrosterone DHEA (8 am and 8 pm)

� Blood

� Homocysteine � Intracellular ATP

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� Intracellular glutathione (redox balance) � Malondialdehyde (lipid peroxidation) � 8-hydroxydeoxyguanosine (DNA oxidation) � Interferon-gamma (IFNg) � Interleukin-1 (IL-1) � Interleukin-6 (IL-6) � Interleukin-10 (IL-10) � Tumour necrosis factor alpha (TNFa) � NF-kappaB � Vitamin B2 (FAD and riboflavin) (whole blood) � Vitamin B6 (whole blood) � Vitamin D � Ubichinon (Q 10) � Selenium (whole blood) � Zinc (whole blood) � Magnesium (whole blood) � Differential lipid profile

3. Measurement of EMF exposure1

In general, a wide variety of forms of EMF exposure (e.g. from cordless phones, wireless internet access, electrical installations and electrical devices in the building, mobile phone base stations, radio and TV transmitters, high-voltage lines or transformer stations) may be the root causes of health problems. EMF measurements should be planned and carried out by specially trained and experienced measurement engineers. See e.g. http://www.salzburg.gv.at/adressen_elektrosmog.htm. After the measurements have been commissioned by the patient and carried out, the results should be discussed with the attending physician or a physician familiar with the issue. The measurements should be carried out in accordance with relevant standards, e.g. the guidelines of the Professional Association of German Building Biologists (VDB-Richtlinien). In addition to the readings, the measurement report should include suggestions for a potential reduction of exposure.

Basic measurements

Low-frequency alternating magnetic fields

Isotropic magnetic field sensor (for all spatial axes) in the frequency range from 5 Hz to 2 kHz, e.g. near the bed, near the desk with source identification (short-term orientation measurement); in addition, long-term measurements e.g. during the night can be useful.

Low-frequency alternating electric fields

1 EMF measurements are not covered by statutory health insurance.

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Isolated isotropic electric field sensor (for all spatial axes) in the frequency range from 5 Hz to 2 kHz, e.g. near the bed, near the desk with source identification.

High-frequency electromagnetic radiation

Broadband measurements and/or band-selective measurements of common frequencies in the high frequency range, e.g. GSM base stations (900 and 1800 MHz), DECT base stations (1900 MHz), UMTS (2100 MHz), WLAN (2450 and 5000 MHz), possibly WiMAX (3400-3600 MHz), LTE (2500-2700 MHz), within a defined measurement space such as the head and torso area on the bed, or the desk chair, with source identification (e.g. acoustic diagnosis); identification of maximum reading; peak detector.

Additional measurements

High-frequency electromagnetic radiation

Frequency-selective measurements (individual frequencies) of common frequencies in the high frequency range, within a defined measurement space such as the head and torso area on the bed, or the desk chair, with source identification; identification of maximum reading; peak detector. The measurements should be adapted to each individual case, e.g. to account for short-wave transmitters, radar, “dirty power” and other high frequency sources.

Benchmarks

The following aspects should be taken into account when evaluating the readings in each case: duration of exposure, exposure during the night or the day, multiple exposure to different EMF sources, additional exposure to noise, chemicals etc., patient’s individual regulation capacity status. Based on epidemiological studies (BioInitiative 2007, Kundi and Hutter 2009) and measurements relevant in practice (Standard of Building Biology Testing Methods, SBM 2008), the Austrian Medical Association ’s EMF Working Group has recommended preliminary benchmarks. Irrespective of the ICNIRP recommendations for acute effects, the following benchmarks apply to regular exposure of more than four hours per day.

High-frequency electromagnetic radiation (as power flow density)

� ≥1000 µW/m² (≥1 mW/m²) very far above normal � 10-1000 µW/m² (0.01-1 mW/m²) far above normal � 1-10 µW/m² (0.001-0.01 mW/m²) slightly above normal � ≤1 µW/m² (≤0.001 mW/m²) within normal limits The benchmarks listed are intended to be applied to individual types of radiation, e.g. GSM, UMTS, WiMAX, TETRA, radio, TV, DECT or WLAN, and refer to peak levels. The benchmarks do not apply to radar, which must be evaluated separately. Highly critical types of radiation, such as periodic signals (mobile telephony, DECT, WLAN, digital broadcasting…), should be critically evaluated, especially if levels are far above normal, while less critical types, such as non-pulsed or non-periodic signals (USW, shortwave, medium and long wave, analogue broadcasting), may be considered more leniently.

Low-frequency alternating magnetic fields

� ≥400 nT (≥0.4 µT) very far above normal � 100-400 nT (0.1-0.4 µT) far above normal

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� 20-100 nT (0.02-0.1 µT) slightly above normal � ≤20 nT (≤0.02 µT) within normal limits The benchmarks are intended to be applied to the range up to and around 50 Hz; higher frequencies and distinct harmonics should be more critically evaluated. Mains current (50 Hz) and traction current (16.7 Hz) should be assessed separately. Long-term measurements should be carried out – also and especially during the night – if intense and frequent field variations occur over time; in such cases, evaluation should be based on the arithmetic mean over the period of exposure.

Low-frequency alternating electric fields

� ≥10 V/m very far above normal � 1.5-10 V/m far above normal � 0.3-1.5 V/m slightly above normal � ≤0.3 V/m within normal limits The benchmarks (potential-free measurement) are intended to be applied to the range up to and around 50 Hz; higher frequencies and distinct harmonics should be more critically evaluated.

4. Prevention or reduction of EMF exposure

Preventing or reducing EMF exposure after consultation of a measurement engineer is advantageous for several reasons:

a) to prevent and reduce risks to the individual and to public health, b) to treat the causes of EMF syndrome and c) to aid in identifying any links to health problems.

There are numerous potential causes for EMF exposure above normal limits, and this guideline can only give a few examples. Further information can be found, for instance, in the building biology checklist “Gebäudecheckliste Baubiologie” (Land Salzburg and VDB 2009) as well as in the information folder on electrosmog (Land Salzburg 2009), which also lists contact data of measurement engineers, sources for measurement devices and materials to reduce exposure. In most cases, it will be necessary to consult an experienced measurement engineer.

Based on documented cases, it is useful to recommend that patients take certain measures (also as preventive measures) to eliminate or reduce EMF exposure, which may lead to an alleviation of health problems within days or weeks. Such measures include the following:

� Disconnecting (unplugging) the power supply of all DECT cordless phones – the use of “classical” cord phones is recommended instead.

� Disconnecting (unplugging) the power supply of all WLAN access points or WLAN routers. (NB: Many LAN routers now come equipped with additional WLAN.)

� Disconnecting the power supply in the bedroom (switching off the fuse) while sleeping. – NB: The benefits should be weighed against the potential risk of accidents and the use of a flashlight should be recommended.

� Disconnecting the power supply to all non-essential electric circuits, possibly in the entire flat or building. NB: See note above.

� Moving the bed or desk to a different place with lower exposure, such as another room or floor; in case of external high frequency sources, rooms facing away from the source should be chosen.

� Discontinuing use of certain appliances and lamps.

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� Retrofitting the electrical wiring of the building to reduce residual current and equalising current (installation of a residual current device RCD).

We also recommend following the 10 medical rules for cell phone use published by the Vienna Medical Association : http://www2.aekwien.at/media/Plakat_Handy.pdf.

5. Diagnosis

A diagnosis of EMF syndrome will largely be based on a comprehensive case history, focusing in particular on correlations between health problems and times and places of EMF exposure, as well as the progression of symptoms over time. In addition, measurements of EMF exposure and the results of additional diagnostic tests (laboratory tests, cardiovascular system) serve to support the diagnosis. Moreover, all other potential causes should be excluded as far as possible. We recommend that the code Z58.4 (Exposure to radiation) under the International Classification of Diseases (ICD-10) be used for EMF syndrome for the time being.

6. Treatment

The primary method of treatment should consist in the prevention or reduction of EMF exposure, taking care to reduce or eliminate all sources of EMF if possible. Many examples have shown that such measures can prove effective. Since sufficient EMF reduction is not possible in all cases, other measures can and must be considered. These include not only keeping additional exposure to a minimum, but also enhancing and increasing resistance to EMF. In some cases, positive effects of holistic medicine treatments have been reported. We take it as given that appropriate treatment will be initiated after diagnosis if the patient presents manifest illness. Regardless of such treatment, the above-mentioned measures to reduce exposure should also be taken. There is increasing evidence that a main effect of EMF on patients is the reduction of oxidative and nitrosative regulation capacity. This hypothesis also explains observations of changing EMF sensitivity and the large number of symptoms reported in the context of EMF exposure. From the current perspective, it appears useful to recommend a treatment approach such as those gaining ground for multi-system disorders, with the aim of minimizing adverse peroxynitrite effects. In summary, the following treatment measures appear advantageous, depending on the individual case: a) Reduction of exposure to electric and magnetic fields and high frequency electromagnetic waves. For more information see e.g. the information folder on electrosmog at www.salzburg.gv.at/infomappe-elektrosmog.pdf.

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b) Lifestyle coaching (exercise, nutrition, addictive substances, sleeping habits etc.) and stress reduction measures (reduction of general stress and work stress), as well as methods to increase stress resistance (autogenic training, yoga, progressive muscle relaxation, breathing techniques, meditation, tai chi, qui gong). c) Holistic treatments such as anti-oxidative and anti-nitrosative therapies, trace elements, vitamins, amino acids. d) Treatment of symptoms until the causes have been identified and eliminated.

References

Abdel-Rassoul G, El-Fateh OA, Salem MA, Michael A, Farahat F, El-Batanouny M, Salem E. 2007. Neurobehavioral effects among inhabitants around mobile phone base stations. Neurotoxicology. Mar; 28(2): 434-40.

Blake Levitt B and Lai H. 2010. Biological effects from exposure to electromagnetic radiation emitted by cell tower base stations and other antenna arrays. Environ. Rev. 18: 369–395. Doi:10.1139/A10-018.

Bedard K and Krause KH. 2007. The NOX Family of ROS-Generating NADPH Oxidases: Physiology and Pathophysiology. Physiol. Rev. 87: 245–313.

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Blettner M, Schlehofer B, Breckenkamp J, Kowall B, Schmiedel S, Reis U, Potthoff P, Schüz J, Berg-Beckhoff G. 2008. Mobile phone base stations and adverse health effects: phase 1 of a population-based, cross-sectional study in Germany. Occup. Environ. Med. 2009 Feb; 66(2):118-23. Epub Nov. 18.

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Eltiti S, Wallace D, Ridgewell A, Zougkou K, Russo R, Sepulveda F, Mirshekar-Syahkal D, Rasor P, Deeble R, Fox E. 2007. Does short-term exposure to mobile phone base station signals increase symptoms in individuals who report sensitivity to electromagnetic fields? A double-blind randomized provocation study. Environ. Health Perspect. Nov; 115(11):1603-8.

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Patient questionnaire

Last name, first name, Mr/Ms

…………………………………………………………………………

Place, date ………………………………………………………………………….

a) List of symptoms

How often have you experienced the following health problems in the past 30 days? Please mark the appropriate box in every line.

Symptoms Never Rarely Someti

mes Often Very

often If yes, since

when (month/year)

Anxiety � � � � � /

Tightness in chest � � � � � /

Depression � � � � � /

Difficulty concentrating � � � � � /

Restlessness, tension � � � � � /

Hyperactivity � � � � � /

Irritability � � � � � /

Exhaustion � � � � � /

Fatigue � � � � � /

Anomia (difficulty finding words) � � � � � /

Forgetfulness � � � � � /

Headaches � � � � � /

Dizziness � � � � � /

Sleep problems � � � � � /

Noise sensitivity � � � � � /

Sensation of pressure in the ears � � � � � /

Ear noises, tinnitus � � � � � /

Burning sensation in the eyes � � � � � /

Nervous bladder, urinary urgency � � � � � /

Heart palpitations � � � � � /

Blood pressure problems � � � � � /

Muscle tension � � � � � /

Joint pain � � � � � /

Skin conditions � � � � � /

Other (please state) ……………………………………

� � � � � /

Other (please state) ……………………………………

� � � � � /

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b) Variation of health problems depending on time and location

Which health problems do you perceive to be the

most severe?

Since when have you been experiencing these

health problems?

At what times do the health problems occur?

Is there a place where the health problems increase

or are particularly severe?

(e.g. at work, at home)

Is there a place where the health problems recede or

disappear altogether?

(e.g. at work, at home, other places, at the home of a

friend, on holiday, at your weekend home, in the

woods)

Do you have an explanation for these health

problems?

Are you experiencing stress, e.g. due to changes in

your personal life or at work?

Please list any environmental assessments made,

measurements or measures taken up to now.

Please list any environmental medicine diagnoses

and treatments given up to now.

Other

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c) Assessment of EMF exposure at home and at work

1. Do you use a cell phone at home or at work?

How long have you been using it (years/months)? ____________ How much do you use it to make calls per day (hours/minutes)? ___________ Have you noticed any relation to your health problems? ____________________________________________________________________________

2. Do you have a cordless phone (DECT base station) at home (H) or at work (W)?

How long have you had it (years/months)? ____________ How much do you use it to make calls per day (hours/minutes)? ____________ Have you noticed any relation to your health problems? ____________________________________________________________________________

3. Do you use wireless internet access (WLAN, WiMAX, UMTS) at home (H) or at work (W)?

If yes, how long have you been using it (years/months)? ____________ How much do you use it per day (hours/minutes)? ____________ Have you noticed any relation to your health problems? ____________________________________________________________________________

4. Do you use energy-efficient light bulbs in your immediate vicinity (desk lamp, dining table lamp, reading lamp, bedside lamp) at home (H) or at work (W)?

If yes, how long have you been using them (years/months)? ____________ For how long are you exposed to them per day (hours/minutes)? ____________ Have you noticed any relation to your health problems? ____________________________________________________________________________

5. Is there a cell tower (mobile phone base station) near your home (H) or your workplace (W)?

If yes, how long has it been there (years/months)? ____________ At what distance is it from your home/workplace? ____________ Have you noticed any relation to your health problems? ____________________________________________________________________________

6. Are there any power lines, transformer stations or railway lines near your home (H) or your workplace (W)?

If yes, for how long are you exposed to them per day (hours/minutes)? ____________ Have you noticed any relation to your health problems? ____________________________________________________________________________

6. Do you use Bluetooth devices in your car?

If yes, how long have you been using them? ____________ Have you noticed any relation to your health problems? ____________________________________________________________________________

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