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.



15 thoughts on “ICNIRP’s public consultation of the draft of the RF guidelines is just a gimmick

  1. The reason ICNIRP members claim EHS does not exsit, is because they have not felt the debilitating effects of the radiation, the truth is the only people qualified and expert enough to judge the levels at which the pain dissapears, are those that have been affected these are the true experts.

  2. The submitted comments were promised to be made public. However, it will be completely unknown which comments were accepted and which rejected and on what grounds… ICNIRP will do whatever it will do and will not justify scientifically any of what is doing…

  3. The comments on the draft are not public? Why do they consult the public if this is the case? I heard Rodney Croft saying at BioEM2018 that he will consider the concern raised by those who made comments.

  4. Take a few minutes to check your facts. The vast majority of the review panelists and the vast majority of original authors of the included studies are not ICES members – and do not have industry associations. Perhaps you meant half-vast?

  5. Tom, there are many reviews written over the last 10 years.

    The reviews that you pointed out were written by ICES members and ICES is an openly industry organization. The vast majority of members of ICES are employed by the industry, including telecoms.

    This means there is a serious bias involved in the reviews of science written by ICES, whether you like it or not. The ICES bias is a fact.

    What is of importance, when dealing with the misinterpretations of science in the ICNIRP blue books, is that it is ICNIRP guidelines that are being advertised and very actively propagated by the so-called WHO, what in practice means just the EMF Project at the WHO.

    So, blue books with their cherry-picked misinterpretation of science in them, are of paramount importance because the telecom industry uses the cherry-picked misinterpretation of science present in the ICNIRP blue books as a “scientific” evidence to justify their exposure limits.

  6. The ICNIRP blue books are not the only repository of relevant information. Several reviews contain analyses of individual studies which provide explanations for why some evidence is accepted and some not. Here is a link to 69 major reviews from the past 10 years.


  7. With everyone’s eyes fixed on ICNIRP, no one is out looking for the real troublemakers for whom ICNIRP is a convenient front. That’s the real genius of the scheme.

  8. Tom, read ‘blue books’. There are studies listed and… without any explanations why some evidence is accepted and some not… appears ‘overarching’ conclusion… This is easy way for ICNIRP to avoid any discussion of validity of science. ICNIRP does not want to provide arguments why some data is valid and some is not. They have no interest in scientific debate. They just want to provide guidelines that are suitable for the industry and governments. Scientific debate is not interesting for ICNIRP as they do not have sufficient arguments to support their guidelines. The negation of existence of non-thermal effects by ICNIRP is already ridiculous and demonstrates ICNIRP’s incompetence.

  9. ICNIRP should be held to account, for all the harm it has done to peoples health, i look forward to the day the “Tables turn”.

  10. Si je comprends bien l’icnirp, qui a suggéré les normes de protection des rayonnements non ionisants (téléphonie mobile…) prétend consulter le public tout en annonçant que les commentaires ne seront pas forcément publiés, sans dire sur quels critères il fera son choix et qu’il n’y aura aucune réponse…ça s’appelle se moquer du monde

  11. Simply by getting the WHO to front for their opinions and guidelines… governments listen to the WHO in matters of health… so, it was a very clever thing when Mike Repacholi, Chairman of the ICNIRP, set up the EMF Project at the WHO… this way all opinions of ICNIRP were spread around the world under the “umbrella” of the WHO because Repacholi selected ICNIRP as collaborating entity… even though the EMF Project was then, in the beginning funded by the industry, because WHO had no money for it… governments listened because they “imagined” the health info comes from and is backed up by the WHO… when in reality it was and it is info coming from a bunch of researchers who set up a private club… and the industry is happy to follow ICNIRP “science based” guidelines… it should be called “ICNIRP cherry-picked science guidelines”

  12. How did ICNIRP, merely a German NGO, become so powerful? It seems like a megalith—how did it start?

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