Written evidence submitted by the Physicians’ Health Initiative for Radiation and Environment (PHIRE)

 

Submission to the DCMS Commons Select Committee (22/06/2022)

Inquiry: ‘Connected tech: smart or sinister?

“The DCMS Committee will examine the impacts of the increasing prevalence of smart and connected technology and what needs to be done to ensure it is safe and secure for its users.

The Connected tech: smart or sinister? inquiry will explore how devices including smart speakers, virtual assistants such as Alexa and Siri and wearable tech such as Fitbits, are reshaping life in homes and workplaces and across towns and cities.

 

About the responding organisation

The Physicians’ Health Initiative for Radiation and Environment (PHIRE) is an independent association of medical doctors and associated specialists assembled for the purposes of improving education regarding health effects of non-ionising radiation (NIR).

We collate research produced globally on this issue, share and critique it, and also conduct our own research. We use the resulting knowledge to help educate ourselves and others, improve best practice guidance, and facilitate the protection and support of vulnerable groups.

 

Reason for this submission

We have overriding concerns about the important health consequences of wireless technology.

 

Further information

Additional evidence in support of our inquiry and consultation responses:

PHIRE & BSEM 2020 NIR Consensus Statement (phiremedical.org)

Inquiry questions and responses

What has been or will be the most important impacts of increasingly prevalent smart and connected technology in our lives, including in the home, in the workplace and in our towns and cities, and are they necessarily better than current systems?

As set out in detail in the referenced PHIRE & BSEM 2020 NIR Consensus Statement, and as we further affirmed in responding to HMG’s recent Biological Security Strategy consultation, the most important impact has been, and will for the time being continue to be, the deleterious biological effects of exposure to non-ionising radiation (NIR) emissions emanating from such technology.[1]

The majority of independent, peer-reviewed scientific studies and expert opinions show that radiofrequency radiation (RFR) emitting systems currently in use undermine human, animal, and plant health and resilience.[2] In the context of copious evidence of harm below guideline levels of exposure, as well as deficient communication of potential and demonstrated hazards and risks, proliferation of such wireless tech is causing preventable damage to public and environmental health. Given the absence of proper health and safety and environmental impact assessments, the unchecked proliferation of such wireless tech is unethical and multiple legal actions are currently underway, including here in the UK, in order to correct this.[3]

The public have never been afforded the rightful opportunity to either provide or withdraw their informed consent to exposure which, given the rapid spread of this radiation throughout our environment, is by now essentially impossible to avoid. Nor have citizens been provided with democratic representation/recourse on this and related issues. Instead the wireless/IoT agenda has been deployed regardless of the concerns raised.[4] As such, it should be clear that the present agenda runs entirely contrary to British values and represents a threat to not only health and well-being but also to trust, security, and democracy.

Some so-called ‘smart’ technology may be considered to be “better” than current systems in certain respects (e.g. cost, convenience, efficiency, interoperability); but it should be recognised that this is rarely “necessarily” the case, and that concerns have been raised that (short-term) benefits may be significantly outweighed by biological harm, rights infringements,[5] and other (long-term) costs.[6]

Besides numerous demonstrated as well as potential human health effects, there are wider direct ecological and indirect environmental problems associated with NIR emitting technology.

A growing body of research suggests that plants and wildlife are being adversely impacted by NIR, with insects appearing to be particularly profoundly affected. For instance, a recent substantial three-part scientific review titled “Effects of Non-Ionizing Electromagnetic Fields on Flora and Fauna” (2021) noted that: “Numerous studies across all frequencies and taxa indicate that current low-level anthropogenic EMF can have myriad adverse and synergistic effects, including on orientation and migration, food finding, reproduction, mating, nest and den building, territorial maintenance and defence, and on vitality, longevity and survivorship itself.”[7]

‘Smart’ tech also has a growing carbon footprint, with related energy consumption projected to escalate significantly,[8] using up to 20% of the world’s electricity by 2025 according to one estimate.[9] Any gains in energy-efficiency are being cancelled out by greater use of the technology. It should be noted that the wireless/IoT agenda also has an insatiable need for rare earth minerals and other scarce resources and generates a significant, growing proportion of the vast quantities of toxic/unrecyclable e-waste that the world now produces (53.6 million tonnes in 2019 alone).[10]

Contrary to widespread greenwashing by industry, ‘smart’ technologies are therefore incompatible with Government commitments to sustainability and to addressing climate change. Over 700 research scientists at universities and engineering schools in France have publicly registered their opposition to the deployment of 5G: “At a time when we have no other reasonable solution than energy sobriety to ensure a liveable future, the very idea of deploying this network and the extraordinary industrial production that accompanies it is crazy - obscene, even.”[11]

“Wired infrastructure is inherently more future-proof, more reliable, more sustainable, more energy-efficient, and more essential to many other services. Wireless networks and services are inherently more complex, more costly, more unstable, and more constrained.” – Dr Tim Schoechle, Senior Research Fellow, National Institute for Science, Law and Public Policy, Washington DC.[12]

At PHIRE our primary concern, however, is health, and there can be no argument that the benefits of further deployment of NIR emitting technology can offset the very real and present health damages. Please see our 2020 NIR Consensus Statement for further details and references (link below).

References:

1. PHIRE (2020). 2020 NIR Consensus Statement: https://phiremedical.org/2020-nir-consensus-statement-read

2. Powerwatch (2022). Bias and confounding in EMF science: https://www.powerwatch.org.uk/science/bias.asp

3. Action Against 5G (2022). News: https://actionagainst5g.org/blog/court-appeal-grants-permission-judicial-review

4. European Parliament Panel for the Future of Science and Technology (STOA) (2021), "Health impact of 5G": https://www.europarl.europa.eu/stoa/en/document/EPRS_STU(2021)690012

5. The Ecologist (2017). Smart meters and cell damage from pulsed EM radiation - our health at risk?: https://theecologist.org/2017/apr/11/smart-meters-and-cell-damage-pulsed-em-radiation-our-health-risk

6. This Is Money (2022). Vastly expensive roll-out of smart energy meters described as a 'waste of money' - because equipment will become obsolete: https://www.thisismoney.co.uk/money/bills/article-10405685/ALL-smart-meters-need-replaced.html

7. Levitt, B. Lai, H Manville A (2021). Effects of non-ionizing electromagnetic fields on flora and fauna, Part 2 impacts: how species interact with natural and man-made EMF. Reviews on Environmental Health. 000010151520210050. doi: 10.1515/reveh-2021-0050.

8. Andrae A, Edler T (2015). On Global Electricity Usage of Communication Technology: Trends to 2030. Challenges. 6(1): 117-157. doi: 10.3390/challe6010117

9. Andrae, A (2017). Total Power Consumption Forecast: https://www.researchgate.net/publication/320225452_Total_Consumer_Power_Consumption_Forecast

10. IT World Canada (2022). E-waste, tech’s big dirty secret: https://www.itworldcanada.com/article/e-waste-techs-big-dirty-secret/481142

11. Boycottons la 5G! (2021): https://www.liberation.fr/idees-et-debats/tribunes/boycottons-la-5g-20210501_FH4YLLHMUVCTLBT5ZY7QEW5WDU

12. Electromagnetic Health (2018). Re-Inventing Wires: The Future of Landlines and Networks (2018): https://electromagnetichealth.org/wp-content/uploads/2018/02/ReInventing-Wires-1-25-18.pdf

Are there any groups in society who may particularly benefit from or be vulnerable to the increasing prevalence of smart technology, such as young or elderly people, people with disabilities and people likely to be digitally excluded?

Per the above-cited Consensus Statement, groups that are particularly vulnerable to NIR include:

a) Pregnant women and foetuses, e.g. the science shows that exposure can promote miscarriage, developmental disorders, and mental and physical health problems that may be life-long.[1]

b) Children, who absorb more radiation than adults, whose systems are still developing, and who have a longer time ahead for latent/cumulative health effects to manifest.

c) Elderly people, who have reduced capacity for repair of NIR-mediated oxidative and inflammatory processes. In excess of 90% of RFR studies report oxidative stress,[2] a process which can damage multiple biological systems and is implicated in many diseases of high public health importance such as Alzheimer’s, cancer, cardiovascular disease and infertility.

d) People acutely affected by electrosensitivity (ES) or Electromagnetic Hypersensitivity (EHS), a multisystem medical condition characterised by physical symptoms associated with NIR exposure; similar constellations of symptoms may also be seen in the general population in cases of relatively high NIR exposure. Effects of exposure can be cumulative, and affected persons are already subject to untold digital, cultural, social, and economic exclusion, isolation, marginalisation, and alienation. Please see the final paragraph on p.5 of the Consensus Statement for further information.

e) People with any one or more of a broad range of comorbidities, including cancer and dementia diseases.[3,4] Please see Section 1 on p.4 of the Consensus Statement for further information.

References:

1. Physicians for Safe Technology (2022). Reproductive Health Effects: https://mdsafetech.org/science/reproductive

2. Yakymenko, I et al. (2016). Oxidative mechanisms of biological activity of low-intensity radiofrequency radiation. Electromagn Biol Med. 35(2):186-202. doi: 10.3109/15368378.2015.1043557

3. Physicians for Safe Technology (2022). Cancer and Radiofrequency Radiation: https://mdsafetech.org/cancer

4. Physicians for Safe Technology (2022). Neurodegeneration: https://mdsafetech.org/neurodegeneration

How can we incentivise or encourage design that is safe, secure, environmentally- and user-friendly and human rights compliant?

First and foremost, all stakeholders must work to ensure that current scientific evidence of hazard, together with both precautionary and urgent advice, reaches the entire population: given the dire need for this we must see public health informational policies and campaigns on a scale matching those of the recent past. How many members of the DCMS Select Committee know, for example, that RFR is currently designated by the International Agency for Research on Cancer as a Group 2B Possible Human Carcinogen,[1] and also categorised as high priority’ for reassessment.[2] Additionally, how many DCMS Select Committee members also know that UK health bodies advocate minimising exposure,[3,4] or that the UK’s Chief Medical Officers state that “children and young people under 16 should be encouraged to use mobile phones for essential purposes only”?[5]

More fundamentally, the responsible department (DCMS) and regulator (Ofcom) must be compelled to dispense with ICNIRP’s arbitrary and unscientific guidelines, which include only short-term, thermal effects and hence fail to address well established sub-guideline bioelectromagnetic hazards. Instead, genuinely independent and objective, scientific, biological evidence-based international exposure guidelines should be adopted as an urgent priority. BioInitiative,[6] EUROPAEM 2016,[7] and IGNIR are useful reference points in this regard.[8]

A moratorium should be placed on the deployment of NIR emitting systems with immediate effect, with all stakeholders working to replace such systems with alternatives, and to otherwise minimise environmental exposure levels and protect members of vulnerable groups in particular.

Beyond the above, no new NIR emitting technology (e.g. 5G/6G/wireless charging) should be permitted: the onus must be on those proposing to irradiate our landscape, society, and wider environment to demonstrate the safety and sustainability of their products before deploying same.

The government could and should do much more to signal, lead on, and otherwise incentivise safe, ethical, and sustainable digital trends by working to swiftly implement a future-focused program of ‘low-EMF’ grants, prizes, and public education and information campaigns. This would best be approached on a united cross-party, multisectoral basis, as a matter of most urgent priority.

References:

1.  World Health Organization (2011). IARC classifies Radiofrequency Electromagnetic Fields as possibly carcinogenic to humans: https://www.iarc.who.int/pressrelease/iarc-classifies-radiofrequency-electromagnetic-fields-as-possibly-carcinogenic-to-humans

2. Marques M, et al. (2019). Advisory Group recommendations on priorities for the IARC Monographs. The Lancet Oncology. 20(6): 763-764. doi: doi.org/10.1016/S1470-2045(19)30246-3

3. NHS Go (2019). Mobile phone safety: https://nhsgo.uk/article/2116

4. UKHSA (2020). ‘Radio waves: reducing exposure from mobile phones’: https://www.gov.uk/government/publications/radio-waves-reducing-exposure/radio-waves-reducing-exposure-from-mobile-phones

5. Mobile phones and base stations (2011). Health advice on using mobile phones: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/215711/dh_124899.pdf

6. BioInitiative Report (2019). Conclusions: https://bioinitiative.org/conclusions

7. Belyaev I, Dean A, Eger H, et al. (2016). EUROPAEM EMF Guideline 2016 for the prevention, diagnosis and treatment of EMF-related health problems and illnesses. Reviews on Environmental Health. 31(3): 363-397. doi: 10.1515/reveh-2016-0011

8. International Guidelines on Non-Ionising Radiation (2021). Guidelines: https://ignir.org/?page_id=8

What are the key short- and long-term risks and threats, and how can we ensure the devices, systems and networks of individuals, businesses and organisations are digitally-literate and cyber secure?

Chief among the key short- and long-term risks and threats are the noted adverse biological effects of NIR exposure, and in particular related public health problems (some of which are endemic). Connected tech can be rendered future-proof, if only informed stakeholders insist on it. The science is clear, as are the ethics and the ecological necessity. Change is a simple function of political will.

As noted, wireless systems are broadly understood to be less secure in general and NIR emissions render many devices, systems, and networks unhealthy to use and effectively unusable by the growing numbers (millions) rendered sensitive by exposure. Employing safe, secure, and efficient wired connectivity would thus ensure greater digital accessibility, literacy, and security.

 

How will current geopolitical concerns influence domestic consumers, e.g. regarding standards of imported goods or in how we can deal with cyber threats?

British consumers are likely to wonder why the UK provides less precautionary NIR health information than, sets public NIR exposure limits higher than, and has been performing less original, independent NIR health research than a number of other countries, including Russia and China.

Citizens may also wonder why the UK has not followed France’s example of restricting the use of Wi-Fi in educational settings for young persons and in withdrawing from sale mobile phones whose Specific Absorption Rate (SAR) exceeds permitted levels.[1] According to tests conducted by the French National Frequencies Agency (ANFR) on 95 mobile phone models, just one in ten conformed with regulatory thresholds of 2W/kg,[2] which are set too high to be genuinely health protective in the first place. The UK government and connected health agencies are known to have been notified of this by numerous correspondents but no action appears to have been taken by anyone.

References:

1. Environmental Health Trust (2019). France – Policy Recommendations on Cell Phones, Wireless Radiation & Health: https://ehtrust.org/france-policy-recommendations-cell-phones-wireless-radiation-health

2. Phonegate (2022): https://phonegatealert.org/en/about-international-phonegate-scandal-eng

Do existing frameworks, like data protection legislation and the Public Security and Telecommunications Infrastructure Bill, adequately address concerns with smart technology, and if not, how could they be changed?

Existing frameworks completely omit to address the biological and broader environmental impacts of NIR emitting technology. They could be changed by ensuring that they include/reference:

a) Adequate health protection measures for vulnerable groups in society.

b) Adequate health protection measures for the general population.

c) Adequate environmental protection measures for our wildlife.

d) Other environmental impact related requirements, e.g. addressing resource use and e-waste.

e) A requirement that all communications technology is wired wherever possible.

f) The right of individual citizens to opt-out of exposure in their locality (i.e. informed consent).

g) The full spectrum of adverse potential and demonstrated biological and human health effects.