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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):
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.
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.