WHO draft of EHC for RF is late and incomplete – consultation is futile, at this time

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The very, very long awaited WHO Environmental Health Criteria Monograph on Radio-Frequency Fields (EHC-RF) is finally, but only partly, available. The process of making the EHC-RF is disappointingly slow and disappointingly secretive and disappointingly incomplete.

The EHC-RF text published in end of September is clearly incomplete. There are available only chapters #2 through #12. The very important chapters: #1 (Summary and recommendations for further study), #13 (Health risk assessment) and #14 (Protective measures) are missing from the draft that WHO provided for the “consultation”.

I wrote purposefully the “consultation” because it can not be real, full-fledged, consultation because it is not possible to discuss and comment on texts that are not yet ready and texts that are simply missing. The missing chapters should deal with health risk assessment and protective measures as well as recommend future research needs.

All of the available chapters are incomplete because, as stated on the website, the review of research publications is only till the end of 2012 (!) or in some cases in 2013. Now it is soon the end of 2014 and all research published in 2013 and 2014 is not included in the chapters.

Lastly, and importantly, there is no word about the authors who wrote the EHC-RF draft. This is an essential information that allows readers to put the opinions presented in the draft into proper context and perspective of the opinions previously expressed by the writers of the EHC-RF draft.

I just begun to read the EHC-RF draft but was immediately taken aback by the following statement in chapter #4 – Biophysical mechanisms; tissue heating (lines 548 & 549 of the draft):

Overall, the search for non-thermal effects of RF on biological macromolecules such as proteins and DNA has not generated good evidence to suggest that such effects occur.

It means that EHC-RF does not recognize the existence non-thermal mechanism of RF exposures. Sarcastically, at this conclusion, the whole EHC process could be ended and experts go home. Non-thermal effects do not occur what indirectly indicates that all evidence of non-thermal biological effects that was published to date, in large numbers of studies, is a one big error. Not a very good prognosis for reading further the EHC-RF.

Today, October 6th, 2014, I contacted Dr. Eric van Rongen who heads the preparation of EHC-RF. I asked about the whereabouts of the missing chapters and about the scientists involved in preparation of EHC-RF. This is what he wrote to me in e-mail (published with permission from Dr. van Rongen):


Hi Dariusz,

The missing chapters are missing because they have not been written! What is there is all we have. There is no point in writing a summary if the material is not complete yet and the health risk assessment is something for the Task Group to write. We have been gathering the literature up to the end of 2012 (so it certainly needs updating) and have given descriptions of all studies (except the ones excluded for reasons described). In some cases preliminary conclusions have been drawn, but since these were always the personal opinion of the person drafting the section, we considered it inappropriate to include these in the chapters now released for public consultation. Like the word says, that process is a consultation: we primarily want to know what we missed and whether the descriptions of the studies are correct. The overall analysis of the material is up to the Task Group (the composition of which has not yet been discussed, by the way).

We decided not to provide a list people who contributed to the drafting of the texts at this time. For the public consultation that is not relevant. What matters are the texts, not who wrote them.

Best regards,


The message from Dr. Eric van Rongen confirms that the drafts are not ready, that the health hazard was not yet evaluated and that the composition of the Task Group  to assess the health risk is still unknown.

While ample amount information is provided already in the draft chapters, the missing information makes consultation process just a sham. Interested parties cannot comment on what is not yet written. Written, after the consultation, chapters’ updates and missing chapters will not undergo consultation. For example, the chapter on cancer is missing any conclusions and any mention whether EHC agrees of disagrees with IARC 2011 classification of RF as a possible human carcinogen.

The all above indicates that the process of consultation was started prematurely because the documents for consultation are incomplete and their authorship is anonymous. On the contrary to what Dr. Eric van Rongen says, authorship matters.

Public consultation should be postponed until the whole text of the Environmental Health Criteria is available for all to see and read and comment. Otherwise, this process cannot be called as good governance practices of the WHO EMF Project.


15 thoughts on “WHO draft of EHC for RF is late and incomplete – consultation is futile, at this time

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  4. It is not about whining. It is about the fact that incomplete draft means that it is not possible to comment on it. What if I give you an incomplete text for commenting and then, afterwards, I add my conclusions that you will not see before the final version is published? And this text will be presented as fully consulted with others? Is it in your opinion correct way to perform consultation?. No. It is bad governing practice. It is sham, not consultation. You are absolutely wrong. END OF STORY.

  5. Well, you and Michael could continue whining about the situation or provide some useful suggestions during the consultation period.

  6. By stopping the literature at the end of 2012, WHO knowingly omits the brilliant 2013 epidemiology of Dr. Lennart Hardell. In those 5 studies published in 2013, the Hardell Group found a statistically significant link between cell phones and two types of brain tumors, gliomas (the deadliest of brain tumors) and acoustic neuromas — tumors of the auditory nerve behind the ear near where a phone is typically held. Dr. Hardell openly calls for RF radiation to be re-classified as a Group 1 or “known carcinogen”, as opposed to its current classification as a 2B or “possible human” carcinogen. Dr. Hardell’s earlier science helped IARC, WHO’s cancer committee, decide upon the 2B classification. Yet when Dr. Hardell submitted his 5 studies to the European Union’s science group SCENIHR which was entrusted with evaluating RF standards for all of Europe, Dr. Joachim Schuz refused to include Dr. Hardell’s 2013 studies (20+ years of epidemiological research on cell phones and brain tumors) in the SCENIHR report, thus purposefully diluting the dangers of cell phones and all things wireless.

    Now the same thing is happening at WHO. This is not a review of the science. EHC on RF appears to be another whitewash to allow another “pass” to an industry reaping trillions of dollars each year while an unsuspecting public bears the massive costs — increasing RF exposure which threatens to diminish the quality of life, slow productivity due to lost work time and diminished performance, and potentially break healthcare systems in countries around the world. This is blind short term gain for immediate profit. It is amoral and both the US and Bill Gates should bear part of the responsibility for this farce as the top two contributors to the donations funded-World Health Organization. Do those who give the money have a say in the outcome of WHO’s work product? The question must be asked.

    Dariuz, thank you for this post. How do we contact Eric von Rongen and Emilie van Deventer to express our concerns about the inadequacy of this study from the WHO — a body we assume is there to protect all of us, when in reality it appears to be protecting the telecommunications industry?

  7. Pingback: WHO fact sheet on RF-EMF | Lennart Hardell's blog

  8. My problem are the unfinished documents and the missing, still unwritten, chapters – this is not how consultation should be done. Documents should be ready, including conclusions and recommendations. As it is now, WHO EMF Project is pretending to conduct consultation…

  9. Actually, Appendix X contains a detailed description of the study evaluation process. If you disagree with that description, the consultation is your opportunity to provide comment to the authors. But, pretending that this issue is not addressed by the EHC is intellectually dishonest

  10. I know many people who seem to be affected by their RF exposure but would never consider themselves to be EHS – they’re just having sleep problems, cancer, arthritis symptoms, anxiety or depression, feeling stressed, headaches, unwell, allergies or immune problems. No EHS, just become unwell and can’t work out what it is.

  11. Dear Michael,
    I fully agree with what you said. The draft of EHC on RF is absolutely not ready for any public consultation. WHO EMF Project seems just to pretend that the EHC was “consulted” with the general public and scientists alike. As I said in my blog, it feels like sham, not consultation.
    It also shows how arbitrary is the WHO EMF Project and how poor are governing practices of this organization and its leader, Dr. Emilie van Deventer.

  12. Dear Dariusz,
    I was also disappointed by the information from Dr.Deventer that the literature was only up to end of 2012. That in some cases articles from 2013 were included sounds arbitrary and biased in my view. Because for such an important document you need strict guidelines for the inclusion and exclusion of literature. I appreciate that you need to draw a line and restrict the evidence to be included because otherwise you will never come to an end. What is of greater importance is again the very subjective wording as previously used in documents of the WHO EMF program, What is good evidence? This has to be defined otherwise it is a moral judgement that is without scientific relevance. If they would try to define these terms (good evidence, convincing evidence etc.) it will turn out that this is evidence they don’t like. But is this a sound foundation for an EHC?

  13. And while industry likely influences the outcome of each and every assessment that the governing bodies produce–the people already affected by these–as yet–unwritten NONTHERMAL effects of radiofrequency radiaton remain on the fringes of society. Unable to get assistance in any way, deemed mentally ill, and left to struggle just to survive. Once highly functioning successful folks are now struggling to find shelter, work, food and acceptance. Some, like myself, are potentially going to lose custody of their children because the condtion must be mental if there is no scientific body–like the WHO–willing to look at all the evidence and make the clear and proper conclusions about this. I am sick of those in leadership roles looking at the ‘politics’ of this while so many people are suffering in untold ways. This makes me sick. The WHO can not be trusted if this is the way they operate. How can their conclusions be trusted when ample evidence exists that people are being damaged by RF’s and the anthropogenic electrosmog that we all find ourselves immersed in today. How can they be trusted when many scientific articles have shown these nonthermal effects? I am a mom and a social worker affected by this and guess what–I have been able to uncover research that shows these effects. How about the research showing dna strand breaks? How about the reseerach showing altered protein synthesis? What about the research showing time and time again tha people report the same constellation of symptoms upon exposure and that thousands of otherwise sane and productive people are now affected in adverse ways. Those adverse ways are varied but center around the same constellation of symptoms. How about the fact that these symptoms have remained basically the same for decades and continue into the present!! How about the simple fact that the WHO is suppose to be protecting people and not protecting corporations and industries?? Those who are in the science field would do well to form a group with the expressed goal of educating these dopes at the WHO on the research that exists. If nobody stands up for people like me, then there is very little chance of us surviving in the world that now exists. With people like Mike Repecholli and Dr. (?) Rubin getting the headlines–what chance do we have of getting the truth about RF’s, EMR, and EHS out to the public? If nobody knows about it–then we continue to suffer in silence with no chance of any help coming for us.

  14. Good question… Should ask from Eric van Rongen. Possibly such term would be explained in preamble of the monograph, but preamble is not written yet, or at least not available yet…

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