Today, on November 5, 2020, Rodney Croft, Chairman of ICNIRP, provided response to questions I posed to him and to Eric van Rongen in my Open Message sent out on October 6, 2020.
As I have agreed with Rodney Croft, I am posting the response as such, without any comments of my own.
To better understand the context of question #3 and response to it, please, see earlier post entitled post Influential Australia where is presented discussion on IEI-EMF between D. Leszczynski and R. Croft
My own comments on the manner and the substance of Rodney Croft’s response, as well as some of the more important/interesting comments from readers of my blog (scientists and activists), will be published soon. Any reader of my blog, wishing to be included in this forthcoming commentary, please, send your comments to me at firstname.lastname@example.org .
Response from Rodney Croft
Further to your continued request for response to some statements and questions that you posted on your blog, please see below. Consistent with what you agreed to in your email, it first comments on the nature of the open letter, and then responds to the questions/comments themselves.
A somewhat confused ‘open letter’
Having indirectly heard about your open letter (I don’t read your blog, nor did your emails, until now, pass my spam filter), I had decided not to respond. This is because: 1/ the questions posed were not appropriate for the addressees; and 2/ the ‘questions’ were not sensibly asked.
The first issue is important as it asks, for example, Dr van Rongen to comment on a private discussion over coffee that you and I had back in 2018, and also asks me to personally say what ICNIRP believes about statements that you have made (which I could not do even if I wanted to, because ICNIRP has not considered your letter and accordingly has not commented on it).
The second issue is also important, because answers cannot be given to questions unless they are asked sensibly. We have all heard of what we call ‘loaded questions’, such as ‘have you stopped beating your wife?’, which does not allow for any satisfactory answer as it combines at least two separate questions (e.g. ‘have you previously beaten your wife’ and ‘do you currently beat your wife’), and no indication is given in the question regarding how the two separate questions are meant to be joined. Unfortunately your questions were similarly loaded, which did not allow answers to provide meaning – although perhaps you did not mean to elucidate, but rather sway opinion, I cannot tell. In either case it does not help your readership to get answers that are not informative. Of course if you had simply asked questions about, for example, whether ICNIRP had arbitrarily dismissed certain epidemiological studies, then I would have been in a position to answer those, but you chose not to do that, and rather introduced a range of statements that you believe needed to be incorporated into an answer to your question. In essence, as you had failed to ask questions, but had blended questions with highly contentious statements, this removed any opportunity for an answer to be given. I would note that ICNIRP has an online system for people to provide comments and questions, and for that we have specifically provided separate sections for comments and for questions to help people avoid making the same error.
However, I will try to clarify, where it is feasible to do so, what I, as an individual scientist, believe in relation to what was written in your open letter. I am not writing this on behalf of Dr van Rongen, nor on behalf of ICNIRP.
Addressing the statements/questions
I have numbered my responses using the numbering of your open letter, along with the prefix ‘DL’ (e.g. ‘DL-1’) and included the ‘question’ that you asked in italics.
[DL: for better clarity, questions are now marked as D. Leszczynski-1, -2, -3, -4; and responses are marked as R. Croft-1, -2, -3, -4]
D. Leszczynski-1. ICNIRP assures that every user is completely protected but, at the same time, there is no sufficient research on age-dependency and health-status-dependency of exposures to RF-EMF. How ICNIRP can assure that the reduction factors built into guidelines are correct when there is no such experimental research and the safety provided by the guidelines is solely an assumption. How the user, who begins use of cellphone at young age of 5-6 years and will be using it for the next 80+ years, with years of varying health status caused by diseases and by aging, can be assured of complete safety when research is missing and assurances come from just assumptions.
R. Croft-1:You confuse two issues in this section, the assumption that there is not sufficient research to determine safety, with the question about how safety can be assured. The first suggests that you believe that for science to know something about a particular scenario (e.g. whether a 902.34 MHz exposure for 72 seconds causes an adverse health effect in a 53.24 year-old male), that science needs to have conducted research using that particular scenario. This of course is a misunderstanding of how science works. What is needed in order to determine whether that particular exposure for that particular person will lead to adverse health effects is sufficient knowledge of the relation between exposure and human health, and this may not involve a test of that particular frequency, or that particular exposure duration, or that particular age, at all.
The question is thus whether there is sufficient scientific knowledge to conclude that the physical agent relevant to 5G (radiofrequency electromagnetic fields; RF EMFs) will adversely affect humans. To know this we need to know what the effects of RF EMFs are, how this relates to the frequency and duration of EMF exposure, and whether there are differential effects of RF EMF exposure on humans as a function of such factors as age, gender and infirmity. Science knows a great deal about the relation between RF EMF exposure and human health, including the relative role of the factors described above, and we can use this knowledge to generalize to what will happen in new situations – after all, generalization based on multiple instances is science’s modus operandi. In terms of 5G, the main difference between it and exposure from 4G devices is that ‘some’ 5G technologies use higher frequencies than 4G (e.g. 26 GHz, as opposed to a few GHz). So if science understands what the effect of RF EMF on the body is, as a function of frequency, then it also understands what the situation is at 26 GHz. That is, science does not need to rerun the last 50+ years of research specifically at 26, 26.1, 26.11, 26.111 and so on GHz. If, however, science had found that current knowledge is not sufficient to generalize to other scenarios (e.g. the research across the RF EMF spectrum does not generalize to 120 or 650 MHz exposures), then that could provide good reason to look further into that hypothetical conundrum. But that is not the case, and it is certainly appropriate to conclude that science has a very good understanding of the relation between RF EMF relevant to 5G, and human health.
D. Leszczynski-2. The question is, why ICNIRP arbitrarily disqualified the results of the four epidemiological case-control studies, supported by the brain cancer localization study, that have shown an increase in risk of brain cancer in avid and long term users?
R. Croft-2: Having worked with ICNIRP for some years now, I have not seen any instance of arbitrary disqualification of research. As you would no doubt be aware, science can be very complex, and even though a researcher may put a lot of effort into trying to answer a particular question, it doesn’t follow that their research outputs are useful for furthering knowledge. For example, it is not unusual to see methodological errors such as inappropriate data analysis, or a failure to account for random variation through appropriate statistics. It is also common for data to be valid in the sense that it provides appropriate representations of the real world, but for interpretations of the data to be incorrect, such as when measures of association are used to infer causation, or when data has been interpreted selectively. As a result, papers can sometimes be put aside for good reason, and results from papers can be used that may diverge from the conclusions reached from the original authors. Such decisions require careful consideration of the evidence and the papers, and this is indeed what I have seen within ICNIRP. I am thus surprised that you have accused ICNIRP of being arbitrary, but note that you have not provided any evidence in support of your accusation.
D. Leszczynski-3. Why ICNIRP, as came out in my extensive discussion with Rodney Croft, opposes research on sensitivity to EMF that would employ physiology and biochemistry methods.
R. Croft-3: This is a bizarre (and categorically false) accusation on so many levels. To be clear, I do not believe that physiology and/or biochemistry should be opposed in terms of idiopathic environmental intolerance attributed to EMF (IEI-EMF) research. To be clear, I have never heard ICNIRP discuss the type of research that should be used to address IEI-EMF, have no idea what the members think, and so would never have been in a position to discuss this with you at all. This is merely a figment of your imagination.
It is important to point out that the ‘extensive discussion’ that you refer to relates to conversation over coffee that we had while you were attending a community forum that we at the Australian Centre for Electromagnetic Bioeffects Research were running in Australia in November 2018. I remember that you positioned your request to talk as that you wanted my views on an IEI-EMF research program that you thought would be important, and I agreed to give you some feedback. That meeting consisted of you presenting your ideas, and me having to explain to you why your proposals would not answer the questions that that you believed they would – you were apparently unaware of the flaws in your proposals. My criticisms, however, related to your particular proposals, and did not relate to biological research itself. You may remember, for instance, that the main flaw that I pointed out was that you were not planning on conducting sufficient trials to enable meaningful statistics to be conducted, and thus that any results could only be hypothesis generating and thus not able to determine any of the questions that you had set yourself. To be clear, whatever the endpoint (be it subjective, neurochemical or proteomic), it is crucial to provide a means of differentiation between effects due to RF EMF, and normal random variation (i.e. not related to RF EMF). To be clear, the relative appropriateness of the end-point assessed will depend on what you are trying to determine. If you are interested in the claim that people can subjectively discern when they are exposed to RF EMF (be it through conscious awareness of the EMF or the presence of a subjectively discernible symptom), then subjective end-points would be relevant. If you are hypothesizing that RF EMF will affect cortisol levels in particular people, then clearly cortisol levels would be important.
D. Leszczynski-4. Please, kindly explain this extremely puzzling statement [“There is no harm associated with 5G”] and please, let me know, what scientific studies were used by ICNIRP in preparation of the Guidelines that assure human health safety while the sufficient scientific research has not been performed.
R. Croft-4: This statement relates to the strong body of science that has shown that exposures within the ICNIRP 2020 guidelines will not result in harm, and the assumption that 5G will produce exposures that are within the ICNIRP 2020 guidelines. The assumption is supported by recent measurement studies, but of course if someone wanted to generate 3G, 4G, 5G, Bluetooth or FM radio-related signals at levels sufficient to exceed the above exposure guidelines, whether the resultant exposure would cause harm would depend on a range of factors. Your commentary (as opposed to your question) suggests that you are concerned about there being enough research that has specifically used particular EMF frequencies. If that is indeed your concern, then that is addressed in response DL-1 above. In terms of the studies used, there are many thousands of studies that have been used, with key or exemplar papers cited in the guidelines themselves.
5th November, 2020