ICNIRP’s public consultation of the draft of the RF guidelines is just a gimmick

Recently, with several years of delay, ICNIRP finally put out their newest draft document for public consultation: ‘Guidelines on Limiting Exposure to Time-Varying Electric, Magnetic and Electromagnetic Fields (100 kHz to 300 GHz)’.

Reading the ICNIRP’s announcement one might be misled by its candor:

“As part of the development of the guidelines, ICNIRP has regularly given draft guidelines presentations to encourage critique and discussion from the many experts who are not members of ICNIRP. From this interaction we believe that the draft guidelines have developed substantially, and in particular into a logical, rigorous and transparent means of providing safety for both general public exposures and workers exposed to radiofrequency fields as part of their occupational duties. Now we expect through this Public Consultation to receive the detail required for further robust critique of this public health document.”

Readers of these words may get an idea that ICNIRP is genuinely interested in the opinions of the general public and that the submission of comments will matter.

Well, from my experience, nothing could be farther from the truth.

Reading further the announcement of ICNIRP’s public consultation comes the following, disturbing, statement (emphasis added by DL):

“At the end of the consultation phase, ICNIRP reserves the right to publish all comments. With your explicit consent, your identity (i.e. your last and first name, and when relevant your affiliation and organization) will be added. Otherwise, the comments will be shown anonymously. When all comments have been considered, a short feedback will be provided via the website on how ICNIRP dealt with the comments. For time constraints, though, no individual replies will be formulated.”

It is a very typical way how ICNIRP is dealing with the science.

In ICNIRP’s ‘blue books’ all evidence is diligently listed = comments will be published. Then, in ‘blue books’, without any discussion of specifics why & what scientific evidence was taken into account or excluded, a final conclusion appears = a short feedback will be provided via the website on how ICNIRP dealt with the comments.

No any criteria for evaluation.

It was very neatly summarized by Chris Portier in his plenary lecture at the BioEM 2015 in Asilomar, CA, USA. Portier stated that when looking at the reviews of the science published by ICNIRP, as well as by SCENIHR and SSI (Swedish Radiation Protection Agency), none of these organizations provides public with the science evaluation criteria they use: “No publicly available evaluation criteria”.

It also sounds pretty hypocritical when ICNIRP states that: “For time constrains, though, no individual replies will be formulated”. It means that it is OK for ICNIRP to have many years delay with providing an updated RF exposure guidelines but it would be too much (sarcasm!) to delay the process further, by a couple of months, to provide responses to individual comments. This way ICNIRP evades responding to the specific points in the specific comments submitted during the public consultation.

And what’s the rush? Why suddenly a few months to provide answers is too much of delay for the ICNIRP? The answer might be simple – telecoms would like to have guidelines ready because the launch of 5G networks was not only heralded for 2019 and 2020 but also it costs a lot of money if delays continue.

So, ICNIRP asks for comments. Claims that will consider all of them. But, in the end, nobody who submitted comment will know what comments were considered and what not, and for what reasons.

But this lack of interest in opinions of others, non-ICNIRP scientists, is well known for ICNIRP. In 2012, when I asked ICNIRP to join a round-table initiative to discuss differences in interpretation of the scientific evidence between ICNIRP and BioInitiative, I received the following e-mail message from then ICNIRP Chairman, Rüdiger Matthes:

“We [ICNIRP] do not consider that participation in the suggested Round Table would bring any added value to our science-based approach.”

Conclusion: ICNIRP discusses only with the scientists it chooses itself. It does not debate science with anybody and everybody. That is why individual comments will not receive individual responses. It would be too “messy” and unnecessary “trouble” for ICNIRP to reveal in detail what they really think is good or is bad science.