Comments from David Gee of EEA

Dear Dariusz,

Your letter came at a most propitious time: I have just finished reading Ehrlich & Ehrlich on “Can a collapse of global civilisation be avoided”? (Proc Royal Soc., Feb 6th 2013).

This is both a sober and compelling summary of why such collapse is a feasible scenario and a call to action by concerned scientists and decision makers to help avert such a collapse. 

Such pessimistic scenarios have been sketched out before, but the difference between now and, say,  the 1970’s calls for limits to conventional economic and population growth is that mainstream organisations, (IEA,FAO,World Bank,the Davos people etc)  and even “progressive” big businesses, are saying pretty much the same thing, though with varying degrees of optimism about the capacities of  homo sapiens (really? perhaps h. tragicus would be more accurate?) to “change course” (BCSD, 1992,WBCSD,2010).

The Ehrlich article has re-galvanised me, after a little period of relative slump, following the publication of vol 2 of “Late Lessons from Early Warnings” (EEA,2001, 2013), to throw my new post retirement time resources into  disseminating the main messages of Late Lessons, (which includes the mobile phones issue-Hardell et al chapter from LL2 attached), as well as much broader themes ,such as climate change ,invasive alien species, ecosystems resilience, nanotechnolgy, the future innovative pathways for agriculture, precautionary science, and the precautionary principle: relevant chapters from LL2 attached for your interest and hopefully dissemination to your networks.

It follows that I am in support of the principle behind your proposed initative on one of these themes ,EMF-RF from mobile phones, which is to help render more transparent  the divide between the ICNIRP and Bioinitiative groups, especially in light of the more scientifically balanced group assembled by IARC which reached a conclusion that more supported the Biointiative view than that of ICNIRP.

However,  your initiative. invites a cou[ple of general points.

Firstly, at this point in the history of mobile phones technology, one would not expect scientific consensus, because the early warnings of potential harm, from brain and other head tumours, for example, are based on time  trends that are too short to provide unambiguous evidence of harm, or no harm. On the latter, IARC, for example,  will not say an agent is not carcinogenic until there has been at least 30 years of reliablly negative evidence-see the Preamble to the IARC Monograph programme.

By way of comparison with EMF,  the evidence for lung cancer and tobacco, at 15 years since widespread exposure began (first WW and thereafter), was largely negative. The evidence on tobacco and lung cancer only became clearly positive, and “convincing”,  in the 1940s and 1950s, with perhaps the 1957 statement of the MRC in the UK ,or the US Surgeon General’s report of 1964, marking the time when the scientific establishments accepted that tobacco causes lung cancer, some 40 years since mass exposure began.  And the tobacco epidemiology was not confounded by ubiquitouis exposures of all control groups to the same agent as is the case with EMF which means that clear evidence of harm may be more difficult to establish than it was for tobacco. 

It is also worth observing that Fisher, the father (?) of modern statistics, refused to accept the evidence on tobacco and lung cancer even after the scientific establishment had done so, largely because, at least during the initial years after Doll’s 1951 Doctor’s study,  of  fears for the reputation of the then nascent science of epidemiology, and later because of his deep dislike of Doll which lead to personal attacks as well as a refusal to accept his evidence, even though it had been quickly replicated by others. Given the intense level of some of the personal attacks on Bioinitiaive scientists by ICNIRP representatives, there will be a similar failure to bridge the scientific gaps between them.

Secondly, because of this latency/controversy  point, it will be much more useful for decison makers to clearly see the range of possible scientific opinions, and in prticular how they were arrived at,  than to try and force a scientific consensus out of a complex, uncertain, and legitimately contested biological reality. Scientific dissension in these circumstances needs to be explained rather than squeezed into an unhelpful consensus ,even if it were possible to do so, which I doubt.

Both Sarewitz, with respect to his recent experience with an expert committee on geo-engineering (Sarewitz, 2011) and Stirling (“Keep it Complex”, Nature 468,1029-1031,2010)) have also noted the value of many voices, rather than constrained consensus, on scientific issues which are uncertain and where the knowledge to ignorance (or the better term, “nescience” ) ratio is low, ie little knowledge and much ignorance.

As Sarewitz observes:

 “The very idea that science best expresses its authority through consensus statements is at odds with a vibrant scientific enterprise. Consensus is for textbooks; real science depends for its progress on continual challenges to the current state of always-imperfect knowledge. Science would provide better value to politics if it articulated the broadest set of plausible interpretations, options and perspectives, imagined by the best experts…….

On the other hand, you might say that the attempt at consensus over climate  change, by the IPCC, is  necessary given the consequences of being late with efforts to avoid it and therefore the need to persent a consensus on the evidence for action as soon as possible: and that the same could be said for the potential harm from mobile phones, especially given the widespread exposures ,particularly to children and young adults, a situation that cries out for the relatively inexpensive and precautionary measures to limit at least head exposures….Science might instead borrow a lesson from the legal system. When the US Supreme Court issues a split decision, it presents dissenting opinions with as much force and rigour as the majority position. Judges vote openly and sign their opinions, so it is clear who believes what, and why — a transparency absent from expert consensus documents. Unlike a pallid consensus, a vigorous disagreement between experts would provide decision-makers with well-reasoned alternatives that inform and enrich discussions as a controversy”.(D. Sarewitz The voice of science: let’s agree to disagree Nature Vol 478 Pg 3, 6 October 2011).

A more promising way forward towards getting action on reducing the possible  risks from mobile phones might be to invite say two or three represesenatives from the ICNIRP and the Bioinitiative groups to an authoratative scientific forum to render transparent their paradigms, models  and assumptions, and their reasoning in evaluating essentially the same scientific evidence in such different ways, revealing in the process their methodological, intellectual ,and maybe funding biases.

They would also be asked to spell out the plausible consequences of being wrong: consequneces are as important as causes when we are at the front end of the histories of potentially harmful technologies:  but consequences  usually receive scant attention in risk assessments, partly because of the artificial separation between risk assessment and risk managemnt.

I have had some experience of such an exercise having organised a workshop at the EEA where 4 case studies were chosen because of the very divergent evaluations of essentially the same evidence: RF from mobiles; ELF from power lines; pesticide spray  drift; and the  ubiquitous chemical. BPA. Representatives from two top expert committees in each case where invited to explain their different evaluations. It was very revealing:  and there  was no revealed animosity in the meeting!

There are a couple of scientific bodies who might be interested in hosting such an event: the newly created Swedish Environment Council, which was set up explicitly to render transparent ,and minimise the differences in, divergent evaluation of the evidence on emerging and contested issues; and the French health and environment Agency ,ANSES, which is getting a good reputation for not running with the scientific establishment on emerging and controversial issues , eg on BPA , GMOs, and RF recently.

I have good contacts with both groups and may be able to persuade one of them (or perhaps a joint venture)  to organise such an event. 

What do you think?

I have taken the liberty of copying in the authors of the Late Lessons chapters that I attach as, with the exception of Hardell of course, they deal with other controversial issues and may have experiences to share about the general issue that you raise.

I am sorry that this is a longish and broader response to your timely initiative but I hope it helps us to take forward  your basic intention  of helping decison makers to  take timely action on unecessary and potentially harmful RF exposures from mobile phones.

Best wishes,



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