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Mast-Victims comments on Sir Richard Adams EESC / EHS counter-opinion
United Kingdom Created: 18 Jan 2015
Dear honorary members representing the European Economic and Social Committee TEN Section on electro-hypersensitivity.

Regarding the EESC own-initiative opinion on electro-hypersensitivity it has come to our attention that an alternative text is being put forward at the last moment by EESC member Sir Richard Adams.
A representative from Mast-Victims.org was present at the hearing in Brussels, 4. nov. 2014 and we find it alarming that Mr. Adams is introducing an alternative version to the already debated, voted and amended text at such a late stage in the process. We have read Mr. Adams alternative text and present the following short comments that we sincerely hope you will consider.

Re. 1.2:
The referred SCENIHR report does not answer the question it was tasked with investigating! namely: are there possible health risks from exposure? Instead the SCENIHR report limits its conclusions to whether there is conclusive evidence. For what the SCENIHR committee was specifically asked to answer, see page 2 (“Terms of reference”) in this document:
For more info see the comprehensive commentary from the BioInitiative working group: http://www.bioinitiative.org/potential-health-effects-emf/

Re. 2.1:
Question: does the author, for the reasons given in 2.1, contest the term “peanut allergy” that implies exposure to peanut is the cause of a host of different symptoms that are shown to be related to peanut exposure although the mechanism of action is currently unexplained? Would the author contest the right of affected people to avoid exposure to peanut? Would the author even argue against the marking of products containing peanut?

Re. 3.1:
Again, the author's demand for “conclusive evidence” is incompatible with public health protection and irresponsible regarding an agent (EMF/RF) that the majority of the population is already and continuously exposed to. The claim that exposure does “not produce any known adverse health effect” is misleading in the context of ICNIRP guideline levels as the correct word to use in that context is: “established”. The ICNIRP criteria for “established” effects is equivalent to: conclusive scientific proof. As a result of those criteria, ICNIRP recognises only consistently reproducible thermal effects that obviously don't even require the exposed to be alive! It is thus clear that ICNIRP guidelines are incompatible with public health protection (which, of course, is about protecting the alive population).

Re. 3.3:
The author states clearly that “basic data for evaluating some risks is still limited, especially for long-term, low-level exposure”. Since that matches the exposure profile of the majority of the population, it must surely justify the Precautionary Principle with regards to EMF. Please note that the ICNIRP publication: “GENERAL APPROACH TO PROTECTION AGAINST
NON-IONIZING RADIATION” makes a clear statement regarding the need to protect the vulnerable in society.
From the section ”People being protected” (page 546):
“For example, children, the elderly, and some chronically ill people might have a lower tolerance for one or more forms of NIR exposure than the rest of the population. Under such circumstances, it may be useful or necessary to develop separate guideline levels for different groups within the general population, but it may be more effective to adjust the guidelines for the general population to include such groups”.
source: http://www.icnirp.org/cms/upload/publications/ICNIRPphilosophy.pdf

Re. 3.4:
It is confusing that the author first demands conclusive proof of highest possible scientific level (3.1) and then in 3.4 chooses to refer to lower quality studies relying on exposure to single frequencies and subjective reports. Some of the referenced negative studies even hint at psychological reasons without providing compelling evidence to support such claims.
While it is true that EHS studies are not all consistent, there are published double-blind studies showing correlation between EMF/EMR exposure and symptoms with a high level of accuracy (f.x.: Rea et. al 1991 / McCarthy et al. 2011). Please consider that subjecting a group of people “sensitive to EMF” to the same frequency/duration of exposure and expecting all to react in the same way is akin to gathering a group of people claiming “food allergies”, giving them all strawberries and then writing the result off as “negative” when only a few turn out to be allergic to specifically: strawberries.

Re. 3.5:
The author's use of the word “disconnected” with regards to reported EHS symptoms is unsupported speculation. Currently, we don't know whether there is a medical connection between the reported symptoms and I doubt the author is medically qualified to support such a claim. 1.13 in the original EESC opinion text mentions that there is published a diagnostics guide for EMF-related health issues by the Austrian Medical Association (so why the author denies its existence in his text is unclear). An update of the mentioned diagnostics guide is under way as a cooperation between European Medical Associations so for the author to claim that “the medical profession does not deal with this syndrome professionally” is incorrect.

Comment on author's reason #4:
It seems that the author misunderstands the point made about asbestos in EESC opinion text.
The point is that in the case of asbestos (and also in the author's own text) “irrefutable scientific evidence” was demanded which only served to delay the necessary public health protection actions with enormous cost to society.

Yours sincerely,

Henrik Eiriksson [a]
phone: +45 36173404
email: henrik {at} solvation.net

Agnes Ingvarsdóttir [b]
United Kingdom
Phone: +44 (0)1684 540 138
email: agnes {at} mast-victims.org

Affiliations: Mast-Victims.org (a,b) & Danish Council on Health-Safe Telecommunications (a).

(download this letter as a PDF via the source link below)
Click here to view the source article.
Source: Mast-Victims.org, H. Eiriksson & A. Ingvarsdóttir, 16 Jan 2015

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