Is ICNIRP reliable enough to dictate meaning of science to the governmental risk regulators?

…This post on ICNIRP was written in 2016… and it is still valid…

This post is a follow up to my posts published on April 4 and April 5, 2016.


In my two blog posts, ‘ICNIRP did it again…’ and ‘Mike Repacholi responds to ICNIRP did it again…’, I presented several reasons why the current modus operandi of ICNIRP is prone to provide unreliable and skewed evaluation of the scientific evidence on EMF and health.

I was strongly opposed by Mike Repacholi, Chairman Emeritus of the ICNIRP, scientist who is responsible for the “birth” of this organization.

In my opinion the major problems of ICNIRP are:

  • it is a “private club” where members elect new members without need to justify selection
  • lack of accountability before anyone
  • lack of transparency of their activities
  • complete lack of supervision of its activities
  • skewed science evaluation because of the close similarity of the opinions of all members of the Main Commission and all of the other scientists selected as advisors to the Main Commission.

I have suggested that the similarity of scientific opinions expressed by the Main Commission members will lead to skewed evaluation of science and I wrote: “…Every expert has opinion. With this opinion he/she comes to work in expert committee. This applies to ICNIRP members too. I hope you are not suggesting that only the scientists of the Main Commission of ICNIRP are able to leave their opinions behind and evaluate the science for its merits alone. However, there is difference between the committee where work scientists with diverse opinions and with the committee where work scientists with very similar opinions. Scientists are humans and act as humans, with all ballasting baggage of pre-existing feelings and opinions. It is certain that the absolute “forgetting” of the pre-appointment opinions is not possible. Thus, scientists with no-effect opinion will easier accept no-effect studies and will look more closely for shortcomings in yes-effect studies. And the same will happen with the scientists having yes-effect opinion. They will easier accept studies showing yes-effect and look more closely for shortcomings in no-effect studies. Here is the problem. If all members of the Main Commission are of the same opinion, the scientific debate will be limited and likely skewed

What is strange and disturbing, is that the European States meekly follow whatever advice they receive from the ICNIRP, blindly trusting group of self-appointed to ICNIRP experts, without critically evaluating what kind of NGO it is, what are its interests and Conflicts of Interests and what is its accountability.

This is a very strange way of dealing with the risk assessment from the seasoned bureaucrats and politicians of the European Union.

It appears, I am not alone with my opinions. In this blog I am presenting one peer-reviewed scientific study on ICNIRP and its activities. Next week I will present another peer-reviewed study, comparing ICNIRP and IPCC.


Recently, I came across an interesting study ‘Not Entirely Reliable: Private Scientific Organizations and Risk Regulation-The Case of Electromagnetic Fields’ authored by Gabriel Doménech Pascual and published in 2013 in the European Journal of Risk Regulation.

Reading this article is like a recap of my own opinions presented in my last two blog posts ‘ICNIRP did it again…’ and ‘Mike Repacholi responds to ICNIRP did it again…’.

Below is a series of shorter and longer quotes from this article. In some of them I put emphasis by bolder font. I strongly advise everyone to read the original manuscript. It is worth the time…

“…private scientific organizations, such as the ICNIRP, are in a worse position than democratic governments when it comes to adapting some risk regulations to scientific progress, those organizations not being reliable enough in that regard…”

Risk of partiality (excerpts)

“…Members of private scientific organizations, by contrast, are not usually elected by universal, free and equal suffrage. Those of the ICNIRP, for example, are co-opted. In this way one mechanism that guarantees to some degree that their assessments and recommendations will tend to satisfy the demands of at least the majority of citizens disappears. In the absence of such a guarantee, the probability that their own interests conflict with those of the majority of voters increases.

One can thus suspect that the best experts in some risk technology – e.g. genetic engineering or nanotechnology –, who may derive substantial revenues and prestige through this expertise, do not have the right incentives, from a social point of view, to objectively assess the risks and benefits of both this technology and its alternatives. It is in their own interest to give opinions that stress the pros and understate or even conceal the cons.

One may also expect that scientists who obtain monetary or reputational benefits from some interests groups will tend to give opinions and recommendations biased in favour of these groups. And there are many ways in which such groups can directly or indirectly provide incentives to experts: funding research programs, recruiting them to write amicus curiae briefs or to participate in public debate, etc. And the most renowned experts are usually able to return favours exerting influence on legislators, courts and the public in multiple ways: not only participating in the works of organizations such as the ICNIRP, but also publishing scientific papers, writing reports designed for use in regulatory settings, writing amicus briefs, acting as expert witnesses, providing support to parties involved in litigation, publishing popular overviews of the debate, etc…”

Lack of accountability and transparency (excerpts)

“…Private scientific organizations such as the ICNIRP, on the contrary, are not accountable to anybody. They can give reasons for their decisions, but they do not need to do so. They usually publish some documents, but it is not mandatory for them to do so. They disclose only the information they want to disclose. Furthermore, their decision-making processes are not as transparent as those of democratic organizations. This lack of accountability and transparency increases the risk of bad decisions being made…”

Lack of plurality (excerpts)

“…Plurality of points of view is of great importance in order to obtain and properly assess the information that will form the basis to make risky decisions, as it is in the setting of limits of maximum permissible exposure to electromagnetic fields. Diversity of perspectives is a conditio sine qua non of dialogue and criticism, which are necessary in order to detect many mistakes, inconsistencies and prejudices. These latter, as Feyerabend noted, “are found by contrast, not by analysis”. “Usually, we are not even aware of them and we recognize their effects only when we encounter an entirely different cosmology”.

The fact that people with different points of view and disparate or even strongly contradictory positions take part in a deliberation facilitates exchange of ideas, transparency, better knowledge of both the considered alternatives and the reasons therefore, criticisms, formulation of new alternatives and argumentative effort. In addition, the heterogeneity of actors tends to neutralize their possible biases and lack of impartiality. “Collective decision making is most likely to amplify bias when it is homogeneous across participants. Heterogeneous biases create the potential for bias correction through constructive conflict”.

The homogeneity of the participants in discussion reduces the quantity and the quality of the information on which judgment should be based, and tends to stifle critical dialogue, to reinforce any common points of view and biases, and to produce extreme outcomes, polarized in the direction of such points of view and biases.

Private scientific organizations are often notably homogeneous. This is clearly the case of the ICNIRP. All its members have similar backgrounds. All of them match the profile of professional scientists working for universities, public research centres or administrative agencies. Alternative or critical views are absent, such as, for instance, those of the firms that produce the most controversial electromagnetic fields and, above all, those of the people exposed to them, whose ability to directly or indirectly influence the current members of the ICNIRP is usually much more limited.

This lack of plurality is not fortuitous at all, but caused by the system used to elect the members of the ICNIRP. As everybody knows, cooptation tends to produce homogeneous, conservative, immobile and not sufficiently innovative groups.

This stands in sharp contrast with the principles underlying current European Union Law. As stated in the Communication from the Commission on the collection and use of expertise, pluralism is a determinant of the quality of the scientific advice. Therefore, “wherever possible, a diversity of viewpoints should be assembled…”

“…As far as possible, fresh ideas and insight should be sought by including individuals outside the department’s habitual circle of contacts…”

Cognitive biases (excerpts)

“…It is well established that people usually suffer from cognitive biases, which can distort their perception and lead them to systematically make certain mistakes in assessing risks. And some of these biases can constitute, to a greater or lesser degree, an impediment for governments and experts to adjust risk regulations to scientific and technological progress…”

“…Scientists are not immune to confirmation bias. One could argue that they are better trained and more prone to challenge their conjectures than laymen. But it must be underlined that the characteristic critical attitude of the former, which has been so important for the progress of humankind, is hardly used against their own opinions, but usually the ones held by other people. Scientists rarely make criticism of their own theories or try to seek information in order to prove how wrong they are. Their criticisms are normally directed against the ideas of other scientists. It is more probable that they search for evidence that could confirm their own theories rather than refute them…”


This term describes the inclination of individuals to overestimate their own performances (overestimation), to mistakenly believe these performances are better than those of others (overplacement) and to have too much confidence in the truth or accuracy of their judgements (overprecision). They are excessively optimistic so to speak…”

“…The consequences of overconfidence should not be underestimated. It [overconfidence] could lead decision makers to take excessive risks and to fail to gather additional information in order to reduce uncertainty and make better decisions…”

Elasticity of scientific theories and elasticity of regulations (excerpts)

“…The procedure the ICNIRP follows in order to produce documents for publication illustrates well this conservative bias characteristic of scientists. Let us remember that such decisions have to be adopted by consensus and, if this cannot be reached, by a threequarters majority of the membership. This rule obviously favours the preservation of the status quo, for a minority of a quarter of the ICNIRP members can block any change in the statements and recommendations made by this organization…”

Conclusion (excerpts)

“…There are several good reasons for governments not to uncritically follow the recommendations made by private scientific organisations such as the ICNIRP in order to regulate some risks, in particular those risks that affect third parties…”

“…Even though new empirical evidence contrary to a mainstream scientific theory might not eventually constitute a sufficient reason to abandon such a theory at the purely scientific level, it may justify a change in the legal rules grounded in that theory…”


In the context of the above quotes and my two blog posts on April 4 and 5, it is good to remember the broader issue. The Environmental Health Criteria is under preparation by the WHO EMF Project, the EMF Project that was hijacked by the ICNIRP


16 thoughts on “Is ICNIRP reliable enough to dictate meaning of science to the governmental risk regulators?

  1. Dear Dariusz, thanks for your great webpage.
    I have several questions to you, so perhaps you have some time to answer them (I am EHS).

    Is the reason for the name of your webpage, that you are in between wrong arguments stated by industry and wrong arguments stated by activists?

    Do you think the statemants by Neil Cherry concerning ICNIRP, i.e.
    300 GHz) are a good source for criticizing ICNIRP and should be considered by the EU or do you prefere today other documents?

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  5. As a lot in this “electromagnetic spectrum” of knowledge about radiation is new to me, from the moment that I became aware of symptoms of something they name electrosensitivity. That was in November 2017. I read and read, learn to understand, and too often I am deeply shocked that governments and media are totally oblivious about this subject. Even ICNIRP and WHO. It is the shame of the century.
    Therefore I feel so much gratitude for your work. I feel understood, seen, and respected, with every word you write.
    Thank you, from the bottom of my heart, for also this article (the latest one is from May 31, 2019, found this above here, today, June 4, though it has been published two months ago, going to read it, study it, and share it on all platforms.

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  9. Dariusz, you may not have any misunderstandings regarding ICNIRP’s role. But, some of those commenting on this issue most definitely do. Let’s review what ICNIRP says of itself:
    “As an independent organization, the International Commission on Non-Ionizing Radiation Protection (ICNIRP) provides scientific advice and guidance on the health and environmental effects of non-ionizing radiation (NIR) to protect people and the environment from detrimental NIR exposure.

    NIR refers to electromagnetic radiation such as ultraviolet, light, infrared, and radio waves, and mechanical waves such as infra- and ultrasound. In daily life, common sources of NIR include the sun, household electrical appliances, mobile phones, Wi-Fi, and microwave ovens.”
    National regulators are free to accept or reject the scientific advice given. Or, accept with the addition of a safety factor – as some countries have already done. ICNIRP does not – and is not equipped to – consider various socio-political factors which may be unique in different national or regional contexts. They deal in science, and nothing but!

  10. I must admit Doctor Leitgebs’ statement makes me blanche. He says :

    “b) However, risk management needs to consider, that safety is not for free. Whatever decision is made based on a risk/benefit analysis, there are parties that will have to pay and others that (hopefully) benefit. Consequently, this requires a broad representation of various stakeholders to find a social compromise.”

    The first question that needs to be asked surely, is :”Are the new (mostly) microwave-based technologies safe?” Is the good doctor really suggesting for instance , that not blowing up the planet with nuclear weapons comes at a cost , and “not for free”? – because one cannot deny presumable that the poor bomb makers presently only get to make bombs to be stock-piled not constantly used and replaced?

    If his ingenious back-door paragraph (b) is NOT to have this result for the world – that we tolerate at least some blowing up of the world to balance the cost to the bomb-makers,- pray exactly how does it fit into the decision-making process at all ?

  11. As professor Leszczynski says : just “the laws of human nature” will skew results the way ICNIRP is set up and operates. This providential (from Repacholis’ point of view) naivety with respect to how hearts and minds operate and colour everything including science, is very striking and familiar from the way other institutional liars behave -liars are only effective when they know how to present an innocent face …
    One thing I feel is not made explicit in this analysis is the fact that we are sort of dealing with an immune system WALL. The belief that never must be breached is the belief that the microwave-based technologies (mostly) are safe. One instance of their unsafety being shown breaches the wall forever. But in terms of scientific theory there is a massive asymmetry between the position that the technology is safe and unsafe. We should not just consider people being more favourable to studies that show a harmful effect and those that show none. We should also acknowledge this asmmetry: One study – well-conducted and designed and conceived – showing harmful effects means the technology is not safe: but studies not finding a harmful effect do not demonstrate safety because harmful effects could exist still in 1,000s of other untested areas or body systems or scenarios.
    So we do not need scientists who are predisposedly neutral towards studies showing effects or not, or who balance each other in terms of dispositions, so much as we need scientists who will address first the question :”Are all the thousands of negative studies with respect to microwave-based (mostly) technologies simply wrong? And If so, how on earth has something so unlikely happened ? ”
    But not asking this question seems to be the unspoken rule – the political correctness, perhaps, of the group as presently constituted. It helps them already, to substitute a weaker question:
    How do we properly adjudicate between ,”weigh”, “positive” studies “against” “negative” studies?
    I don’t know if ICNIRP admits to doing this, but I believe The WHO DOES, it takes a “weight of evidence approach”, which seems to me, although I am a non-scientist, to be scientific nonsense, and a massive failure of scientific integrity.

    So it should surely be enough to have scientists on the committee who have integrity.
    And we can know they lack integrity is they do not want to address this question, stated above.

    This is only too familiar is it not, from other political groups – where the one thing never mentioned is the very truth that would provide enlightenment and a path to resolve problems ?. The monster protects its integrity (so to speak), so an immune system is created to block reception of the truth that would kill the monster.
    How do we breach that immune system?

  12. Norbert, I think that there is no any misunderstanding. First of all, ICNIRP performs review of the scientific evidence. This review is the basis of any recommendations. WHO actively promotes and simply pushes governments around the world to use ICNIRP recommended safety limits. This can be considered as not only recommendation of ICNIRP safety limits but also as forcing implementation of these. The review of science by ICNIRP, that is the basis for the safety limits, is likely skewed because of the faulty members selection procedure used by ICNIRP. This faulty procedure causes that all members of ICNIRP have the same opinion on the matter of EMF and health. This is against the rules, at least in European Union. Matter is still worsened by the lack of transparency in ICNIRP activities and complete lack of accountability. Furthermore, the procedures of checks for the possible conflict of interest are absolutely inadequate. It is as if whatever the member says is to be taken on its face value, without any supervision. You refer to “the better scientific arguments should count”. Yes, it is absolutely so. However, ICNIRP might not be able to provide these because of the skewed, in one direction of scientific understanding, composition of experts. Question is not about “war of convictions”. Question is about thorough and unbiased evaluation of scientific evidence. This does not happen in ICNIRP composed as it was and as it is now.

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  14. While I appreciate a critical discussion, unfortunately, I noticed three major misunderstandings in the arguing which I would like to clarify:
    1. There is a confusion between risk assessment and risk management
    a) Risk assessment in terms of identifying adverse effects and their associated weight of evidence is a purely scientific issue. There should be clear (preset) rules how to evaluate studies and come to an overall conclusion in presence of controversial results or limited data (such as defined by he German SSK). Consequently „believers“ of any kind or stakeholders of any kind should not be involved in this process.
    b) However, risk management needs to consider, that safety is not for free. Whatever decision is made based on a risk/beneffit analysis, there are parties that will have to pay and others that (hopefully) benefit. Consequently, this requires a broad representation of various stakeholders to find a social compromise.
    2. ICNIRP might be criticized for several weak points which do exist including its recruitment procedure and risk communication (I probably would list some different points than you), but overall, it makes a very good job in risk assment and – less sophisticated – in weighing existing evidence. In addition, very important, it provides a convincing scientific rational for its recommendations.
    It should be kept in mind, that it is still up to national and international authorities to take their own risk management decisions such as on the objectives of risk management, the necessary safety margings (in addition to the reduction factors which just account for uncertainties), the adoption of the ALARP principle or to add additional regulations such as how the available exposure cake might be allocated to different sources – such as done by Switzerland.
    The attempt of worldwide harmonization is appreciated since the health of people shoud be given the same importance irrespectiv the region they live in.
    3. There is a another misunderstanding: ICNIRP’s output is recommendations rather than dictates. They are adopted on a national bases just because of their scientific quality and common sense, not less but no more.
    Therefore, instead of accusing ICNIRP (which may be popular in these days), it would be much better to follow the well-known principle: The better is the enemy of the good. In risk assessment the better scientific arguments should count, nothing else. There should be no room for convictions or believes of whatever kind.
    Consequently, whatever interdisciplinary group of scientists is able to perform better in risk assessment is free to present more convincing results together with a more convincing science-based rational.
    Although there are many excellent national committees, up to now I don’t see a better international alternative to ICNIRP.

  15. Great article. This self appointed, self protecting group should have no say.

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