The Precautionary Principle and Regulation of Exposure to Electromagnetic Fields


Basic Considerations

ICEMS (International Commission for Electromagnetic Safety)

Regulation and limitation of exposure to nonionizing radiation was introduced for some occupations and military applications in the 1950s, but exposure standards for the general public and broader occupational categories were not established until the 1980s. At that time distinctly different approaches to standardsetting were applied in the Western World as compared to the Soviet Union, Eastern European countries and China. Efforts of WHO to reconcile the different approaches have not been successful. While the two approaches have some similarities, still there are considerable discrepancies in procedure and resultant guideline levels of most Western countries as compared to Russia, China and Eastern European countries. Furthermore, Italy, Switzerland, Belgium and regional authorities of other countries apply guideline and limit values that are based on still other procedures and considerations.

There is considerable public concern in many countries, especially about possible long-term effects of EMFs, that is at least partially due to these discrepancies and the legitimate scientific controversy surrounding them.

Basis for Limiting Exposure to EMFs

A fundamental error of reasoning can be demonstrated in numerous statements of international and national EMF standard-setting organizations and committees. Its essence is the assumption that science-based, ‘objective’ guidelines have to rely on ‘established’ evidence only. It is significant that none of these documents that abundantly make use of the term ‘established’ make any effort to define it.

Furthermore, this ‘scientific’ and ‘objective’ method is often contrasted to the falsely labeled ‘political’, ‘subjective’ and ‘ultimately arbitrary’ one that is related to the precautionary principle.

For two reasons this line of argument is faulty.

First, any effort to define how results become ‘established’ must acknowledge that the process includes an arbitrary aspect of subjective acceptance. Second, the derivation of an exposure guideline itself can never be based solely on science, i.e. on empirical data and a sound theory that has withstood serious tests to refute it. Guideline decisions are made that contain subjective elements of values or policy.

An illustrative example is the application of safety factors to adjust for variations in environmental conditions and susceptibility in the population that should be protected. These factors are rarely based on evidence and rather introduced by convention or even economical considerations and technical feasibility. In risk assessment all the evidence pertaining to the scientific issues has to be considered and nothing makes it ever ‘established’ except an ultimately subjective decision.

More- or less-standardized procedures for deriving national and international exposure guidelines for issues other than EMF have been developed in the past decades for environmental and occupational factors that are typically based on evidence from epidemiological studies, experimental investigations in animals and humans, in vitro studies and theoretical considerations about the mechanism of action.

Although weight and/or strength of evidence is thoroughly considered, a decisive element of these procedures is their precautionary approach. Because it is recognized that derivation of guidelines is conjectural and open to scientific controversy and discussion, the precautionary approach demands in case of uncertainty the evidence should be weighted to err in the direction that leads to the higher margin of safety. Examples of this procedure can be found in the Air Quality Guidelines for Europe by WHO.

Concerning EMFs, differences in exposure standards are mainly due to different answers to the following questions: What evidence should be used as the basis for the derivation? How should the broad spectrum of EMFs be subdivided? Which aspects of the multidimensional exposure situation must be considered? What are the relevant dosimetric quantities? Which safety factors should be introduced and what values should they take on?

In the face of such complexity, there is a great temptation to take the short cut for answering these questions. In fact, the procedure used by ICNIRP, IEEE, and other national and international standard-setting organizations reduces the problem to answering only the last of the questions stated above. These organizations maintain that the only evidence to start from are immediate short-term effects such as nerve excitations due to induced currents or temperature increase from absorption of...

Read the rest under: http://uh22.umwelt.univie.ac.at/icems/Pp150203.pdf

Informant: Sylvie


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