Dear Ministry of Health,

Given that your Interagency Committee on the Health Effects of Non-Ionising Radiation
has advised you that current levels of RF/EMF radiation (e.g., 3G, 4G, 5G) are not a serious health concern (your online 2021 5G Factsheet says: "recent research has not turned up any unexpected findings"),
and given that the Oceania Radiofrequency Scientific Advisory Association in their 2020 cross-sectional study of 1,995 scientific experimental studies within the ORSAA database (laboratory studies and population-based studies examining biological and health effects of RF-EMR exposures) revealed that the majority (68%) show significant biological or health effects, please provide the list of studies reviewed by the Interagency Committee that justified their advice (absent the Precautionary Principle) to you (and thence to the public) that this accumulating radiation in our environment is of no serious concern. . .
(and, we can only deduce, does not merit stringent independent review and regulation).
Has the Committee overlooked the ORSAA study?

Yours faithfully,
Michael Fleck
Waiheke Action for Ethical Technology

24 July 2021

Deborah Woodley
Deputy Director-General, Population Health and Prevention
Ministry of Health

Dear Ms Woodley

Thank you for your response of 7 July to our OIA request, and for providing the minutes from the last three Interagency Committee meetings. We better understand now how the Committee operates, and who is most pro-active among the members attending each meeting.

According to Committee member Kimbal McHugo, the main purpose of the Committee "is to determine whether the science has changed
to the extent that a review of Health and government policy is needed."

Interesting this, as science is always changing, and there is no fixed 'the science.' This is the essence of the scientific method. So we ask, to what extent must 'the science' change before government health policy begins to truly protect people and the environment?

From our research, the science of EMR safety has been changing at a significant rate, and the evidence of harm is overwhelming.

Your description of Committee expertise and procedures, and your defense of the ICNIRP, appear convincing in print, but in practice? For us at Waiheke Action for Ethical Technology, the Committee's current practice raises important ethical questions:

1) The Precautionary Principle is effectively ignored when evidence is encountered that should trigger alarm. For example, we find it ethically unacceptable that Dr Dockerty speaks of an "un-nuanced view of the Precautionary Principle." Does he mean we are permitted to 'nuance' the meaning of a term so that it accords with one's cognitive bias?

(see Frank – "An opinion piece recommending a moratorium on 5G roll-out pending more research. The opinion is based on a limited review of the research, and un-nuanced view of the precautionary principle." -- John Dockerty)

Scientifically and medically, this principle is the bottom line: Do no harm. The Precautionary Principle demands that even if only one or two peer-reviewed high quality studies show harm, there is cause for halting exposure to this technology until its safety can be verified with certainty.

At present you will find the following in the NZ Draft of the Natural and Built Environments Bill:
The precautionary approach is an approach that, in order to protect the natural environment if there are threats of serious or irreversible harm to the environment, favours taking action to prevent those adverse effects rather than postponing action on the ground that there is a lack of full scientific certainty.

2) There has been virtually no high-quality research on the safety of 5G technology. This has been admitted by the wireless industry.
We would expect this Committee to demand safety testing and require of the Telcos a 'warrant of fitness' for this evidently hazardous vehicle of communication (or 'transport of data'). Where are the regular reports of 3G and 4G safety testing to determine if already questionable standards are adhered to? Mr Gledhill's own company could be reporting on this, although this would be a conflict of interest.

Committee member Simon Cooke-Willis said as much: "a consumer viewpoint is important, to ask questions that consumers might have, such as 'Is this product safe' or 'Is it covered by standards?' ” Caveat emptor.

Can the consumer (or exposed citizen) of wireless data be assured of informed consent? The current MOH Fact Sheet statement that existing research can be applied to 5G, is unscientific and quite implausible. Results of studies involving one set of radiation frequencies cannot be assumed to apply to some of the higher 5G frequencies, especially with the addition of beam-forming technology. Furthermore, the public is not being told by the Telcos or by the MOH that 5G technology will operate on top of and in addition to the existing 3G and 4G systems, upon which it depends.

3) Internal bias.
We must ask, why are engineers and Telco reps who act for vested interests and have no health expertise, sitting on a health advisory committee? Is this Committee really about public health?

In view of the proceedings recorded in the minutes provided, we must also ask why the Committee relies solely on the studies selected by Martin Gledhill and John Dockerty? What are their criteria for selection? As one reads their evaluation of each study, a clear pattern of bias emerges, with phrases like:

"Dave McLean considered that Dr Leszczynski was familiar with the literature but had a different understanding of its implications than himself, and was selective in his choice of literature." (and this Committee is also selective)

". . .but the data were imprecise."
(quite arbitrary, this)

"low quality of some" studies
(also, arbitrary, and arguable)

"Dosimetry is likely to be poor."
(Likely? We expect certainty.)

"insufficient for drawing conclusions" (McLean and Peters: ELF and ALS risk)
(Who determines sufficiency?)

"insufficient evidence" -- FDA being sued, abstracts. (why would anyone attempt to sue the FDA with insufficient evidence?)
"The overall conclusion from the papers is that more data is needed."
(reeks of decades of Big Tobacco statements)

Meanwhile numerous 'red flags' appear in the studies reviewed, yet these are glossed over:
• Brech et al – Found increase in DNA damage in cells exposed to high levels of IF-EMF.

* Gervasi on living within 50m transmission lines = risk Alzheimer's and Parkinson's

• Nunez-Enriquez – A well conducted study, in an area with higher exposures than most, but few exposed cases.

* Berenis -- "concludes that there may be effects" (but Dockerty and Karipidis dismiss instead of pursue further)

• Choi – In contrast to the Roosli conclusions, the Choi review and meta-analysis found evidence linking mobile phone use to increased tumour risk.

• Carlberg – Looked at time trends for thyroid cancers and concluded that they could be consistent with RF from mobile phones being a causative factor.

• Cabre-Riera – Found that higher exposure to RF is related to lower non-verbal intelligence, but cautioned that the nature of the study meant that this could be a chance finding or reverse causality.

• Shih – The meta-analysis found that some sources of exposure were associated with increased risk of breast cancer but others were not. Overall they concluded that RF exposures did give an increased risk.

* Selmaoui – Reviewed research on the effects of RF exposures on melatonin and cortisol and found conflicting results.

* Martin Pall - Claims to find that various microwave exposures cause diverse neuropsychiatric effects
('Claims'? Dr Pall is a pre-eminent researcher in this field.)

* Leszczynski – A catalogue of studies of mmWave exposures on the skin, that concludes that more studies are needed to ensure safety.

* Frank – "An opinion piece recommending a moratorium on 5G roll-out pending more research. The opinion is based on a limited review of the research.

Might the Committee also have "a limited review of the research"? Comprehensive reviews of the research also urge a moratorium.*

Not once throughout three meetings has a red flag raised concern among the Committee. Yet the Committee discusses "dispelling myths about 5G," as if to discount and dismiss legitimate concerns expressed and hazards reported by thousands of New Zealanders, and by scientists and medical professionals worldwide.

May we ask, would the Committee please discuss and justify the 'myths' and propaganda proclaiming 5G: safety -- such as appears on the MOH website?

At the conclusion of each meeting we read:
The Committee. . .advised that there was nothing in the research considered at the meeting that would lead the Committee to consider that any change in current policy was required.

Really?

Conclusion

From what is shown in these minutes, we can only conclude that:

a) The Committee is not comprehensive in its selection of studies, nor unbiased in its assessments. Members, for the most part, rubber-stamp the reports of Dr Dockerty and Mr Gledhill.

b) There is no sign of lively debate at these meetings, while evidence of harm continues to mount and our environment is ever more saturated with EMR. This suggests that some members are not aware of the myriad implications of this technology, or have already fixed an opinion and are merely sitting in.

c) The Committee gives too much credence to ICNRP (whose integrity has been seriously challenged internationally**) and to ARPANSA. Where is New Zealand's sovereignty and our proud tradition of scientific research? Where is recognition of the internationally-lauded research of Dr Neil Cherry (d. 2003) of Canterbury? There is no show of concern, alarm or action regarding this verifiable public health hazard other than to fall in behind the ICNIRP narrative and inadequate safety regulations, and thus maintain the status quo.

The ICNIRP is an NGO of 14 self-appointed members frequently with conflicts of interest, who have no public accountability for their guidelines. Professor
Paolo Vecchia, a former chairman of ICNIRP at a 2008 conference at the Royal Society in London, said this about using ICNIRP's technical guidelines:
"What they are not: Mandatory prescriptions for safety; the 'last word' on the issue; defensive walls for industry or others." (verbatim quote from voice recording)
He strongly emphasised that the ICNIRP guidelines are only technical in nature, and never were intended to be used as safety recommendations for medical or biological issues.

ARPANSA guidelines are based on those of ICNIRP and are less stringent/protective than standards of some countries by 10-1000 times. There is no scientific consensus on safe levels of RF radiation internationally, and there is intense debate on the topic, as biological effects have been demonstrated to occur below even the most stringent current standards.

As you may know, 225 EMF scientists from 41 countries have petitioned the UN and the WHO, urging measures to protect public health.

d) In the last three Committee meetings there has been no reported discussion of environmental effects, or any report on studies, even with two Ministry for the Environment representatives and a senior environmental health officer on the Committee. With the huge increase in EMR in our environment, there is demonstrable harm to trees, birds, bees, other insects.

Furthermore, the generation of EMR is a signifcant factor in climate change. Carbon emissions from data centres will, at present rates, amount to 20% of global emissions by 2025. Reducing EMR emissions while protecting the public is now the primary focus of the Green Party of California and of France (the world's fifth and eighth largest economies.)

e) Discounting the ORSAA review is a serious error. You say their review of 1,995 studies "is of little value." What are your scientific qualifications to make that statement? or to question "good practice" and claim "poor methodology"? Are you actually quoting Dr Dockerty or Mr Gledhill?

The assumption here is that the public must trust these MOH 'experts' rather than the ORSAA 'experts'. Please remember that people trusted 'experts' on tobacco, asbestos, thalidomide, DDT, lead, etc. When the Committee considers ORSAA reports as "grey literature," this is pejorative labeling. Another bias is revealed.

We refer you to the ORSAA submission to the Australian Federal Parliament:
file:///C:/Users/user/Downloads/Sub311%20(5).pdf

f) You conclude your letter saying that your Ministry's advice "is based on the best international evidence available." Seriously? The Committee would do well to consider the judicial review charging Public Health England*** with:
* failure to take into account evidence of high risk to human health
* failure to commission a full and independent assessment of risks
* failure to put in place safeguards for public health
* failure to provide effective info to public re: risks

The critical legal research behind this case draws upon the significant amount of research papers and meta-analysis of research on the safety risks of RF/EMF radiation published in the last two years.

We draw your attention to three examples of such papers, and the research to which they refer:

(1) The 2020 Consensus Statement of UK and International Medical and Scientific Experts on Health Effects of Radiofrequency Radiation: https://phiremedical.org/wp-content/uplo... on-Consensus-Statement.pdf

(2) The expert submission from Professor Tom Butler dated 27 May 2020, supporting the application for Judicial Review against the UK government: https://actionagainst5g.org/wp-content/u... and

(3) the paper published in ACNEM Journal Vol 39 No 1 July 2020 entitled "5G Wireless Deployment and Health Risks: Time for a Medical Discussion in Australia and New Zealand," a summary of which can be found here https://www.acnem.org/news/5g-wireless-d....

In summary, we find the Committee failing to advise the Ministry of Health comprehensively and accurately on the considerable health hazards from EMR, thus rendering the MOH unable to fulfil its duty to protect the health of New Zealanders.

We urgently recommend an independent investigation and revision of the Committee's purpose and procedures, and that a Secretary be appointed other than Martin Gledhill.

We also recommend that all Committee members, in preparation for their duties, are comprehesively introduced to the subject by reading Arthur Firstenberg's The Invisible Rainbow: A History of Electricity and Life (2017, AGB Press), and to consider membership in ORSAA (as well as ARPANSA). ORSAA's five objectives are listed below, for the convenience of the Committee.

Please forward this to all members of the Committee, including those who have resigned in the past year. We are copying this response to Andrew Little, Ashley Bloomfield, Juliet Gerrard, and our regional MPs, urging them to initiate a review, and, with our assistance, consider other actions to bring the inadequacies of this important Committee to the public’s attention.

Sincerely,
Michael Fleck, M A
Michael Vaughan, BSc, M Ed
Waiheke Action for Ethical Technology
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The Oceania Radiofrequency Scientific Advisory Association (ORSAA) offers a non-profit database
of peer-reviewed scientific studies and articles which enables independent searches.

Objectives of ORSAA

1. To promote the preservation of health and human rights by advancing the knowledge and expertise pertaining to the science of non-ionizing radiation through education and other lawfully charitable means. This will be achieved by promoting social and environmental responsibility when adopting new High Frequency (HF) technology with a view to harm minimization.

2. To promote the establishment and maintenance of a program to educate scientists, medical professionals, education professionals, and interested laypersons, by making available and disseminating as widely as possible, all available information relating to scientific research covering man made sources of non-ionizing radiation, environmental impacts and public health and well-being. This will be achieved by the following:

a. Assemble a broad range of scientific experts within the scientific community relating to HF radiation exposure and potential health effects;
b. Provide a forum for discussion and education;
c. Provide educational seminars on the safe use of HF radiation devices; including bringing to Australia the latest overseas researchers to talk on the emerging health issues that are being associated with HF radiation exposure.

3. To promote the establishment of ethical and professional RF Standards that are biologically based for long term benefit of the general public. This association will have no vested financial interest in wireless technology and will investigate research studies relating to radiofrequencies with an independent and unbiased view.

4. To promote the support and encouragement of scientific research applicable to man-made non-ionizing radiation, health and well-being.

5. To assist in research objectives that will identify potential impacts relating to exposure of man-made non-ionising radiation and to establish a sound basis for explaining potential harm(s).

References:

* The 2020 Consensus Statement of UK and International Medical and Scientific Experts on Health Effects of Radiofrequency Radiation: https://phiremedical.org/wp-content/uplo... on-Consensus-Statement.pdf

** “The ICNIRP’s 2020 guidelines published in March of this year, update those published in 1998. The new guidelines include only minor changes to the 1998 guidelines, primarily to accommodate 5G’s extremely high frequency millimeter RFR signals (Barnes and Greenebaum, 2020). It must be remembered the guidelines focus on technical issues and present safety recommendations for the thermal effects of non-ionizing RFR at high levels of exposure over the short-term measured in minutes.
They effectively ignore or deny the existence of non-thermal effects on adults and children and long-term exposure to RFR at low levels. The ICNIRP 2020 Guidelines ignore or dismiss on scientifically spurious grounds the significant body of scientific research since 1998.
The majority of independent scientists consider the ICNIRP and the related EU SCENIHR as ‘captured’ organisations—that is they are heavily influenced by industry-funded researchers and industry itself. Scientists from the ICNIRP, who are also, as indicated, members of SCENHIR and WHO, are accused of conflicts of interest due to their close ties with industry.
An Italian court judgment recently recognised this. In December 2019, Turin Court of Appeal president Dr Rita Mancuso ruled that research reviews carried out by ICNIRP and its members were biased and could not be trusted in determining whether there was a causal link between wireless cell phone use and brain cancer. The court decided that there was such a link, and its judgment was based on extant independent scientific studies, such as those cited herein.”
--Extract from the expert report of Professor Tom Butler dated 27 May 2020 filed in support of the UK judicial review proceedings.
https://actionagainst5g.org/wp-content/u... G.pdf

*** UK judicial review proceedings commenced on 23 March 2021, https://actionagainst5g.org/ and the letter-before-action, https://actionagainst5g.org/wp-content/u...
concerning the health risks posed by 5G technology, to which members of the public are being exposed without their consent or proper consideration by the relevant UK safeguarding authorities.
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