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Bill Casey, MP
Chair
Standing Committee on Health 
House of Commons
Ottawa, Ontario
K1A 0A6

Dear Mr. Casey:

            Pursuant to the House of Commons Standing Order 109, I am pleased to respond, on behalf of the Government of Canada, to the Thirteenth Report of the Standing Committee on Health, entitled, “ Radiofrequency Electromagnetic Radiation and the Health of Canadians ” tabled in the House of Commons on June 15, 2016.

            The Government would like to thank both past and present members of the Committee for their work in preparing this report and welcomes their interest in evaluating the potential health effects of radiofrequency electromagnetic radiation, including cell phones and Wi-Fi.

            Protecting the health of Canadians and their environment is a core function of the Government. A number of actions directed at increasing awareness and responding to Canadians’ concerns related to potential negative health effects from electromagnetic energy have already been initiated. As can be seen in the attached Government Response, the Government is committed to using the best available science to inform its decision making. The Government will continue to monitor the international scientific literature and support awareness on exposure to electromagnetic radiofrequencies while promoting information sharing amongst all levels of government. As described in the Response, action will also be taken on additional recommendations provided by the Committee.

____________________________                           

The Honourable Jane Philpott, M.P.
Minister of Health


GOVERNMENT RESPONSE TO THE REPORT OF THE
STANDING COMMITTEE ON HEALTH ENTITLED

Radiofrequency Electromagnetic Radiation and the Health of Canadians

The Government of Canada has carefully considered the Thirteenth Report of the Standing Committee on Health (the Committee) entitled Radiofrequency Electromagnetic Radiation and the Health of Canadians .  

Canada is recognized worldwide for the rigour with which it gathers, assesses, and incorporates scientific information into its decision making and standards. In the case of electromagnetic radiation Health Canada carefully tracks developments in the scientific literature, in particular studies in relation to adverse health impacts. Health Canada uses a “weight of evidence” approach in evaluating scientific studies, which takes into account both the quantity and quality of studies, and gives more weight to studies which have been reproduced and which meet the highest standards of rigor and control. Canada also recognizes the importance of leveraging scientific expertise from around the world and as such, works closely with organizations like the World Health Organization (WHO), which includes the International Agency for Research on Cancer (IARC). Canada’s approach ensures the protection of the health and safety of Canadians, including our most vulnerable.

Some researchers and advocates question the safety of radiofrequency (RF) energy and the approach applied by Health Canada in assessing the scientific evidence related to developing human exposure limits. While some studies have reported health effects below Canadian and international safety limits the totality of the scientific evidence does not support the link between radiofrequency electromagnetic fields (RF EMF) and health effects.

The Government of Canada agrees to continue to support scientific research and encourages researchers interested in studying the possible health effects of the RF EMF exposure and adverse health effects to make use of opportunities available as outlined below. Additional research helps to increase scientific evidence in this area, to better respond to public concerns and to improve risk communications. To encourage worldwide coordination of scientific efforts on this issue the WHO has published a “Research Agenda for Radiofrequency Fields”, which identifies scientific research priorities related to RF EMF health effects impacts.

The Government’s Response to the Committee’s recommendations is grouped into three broad themes: the need for further research and investigation into possible links between RF electromagnetic frequency exposure and cancer; the need for greater understanding and management of electro-hypersensitivity (EHS); and the need to protect our most vulnerable while enhancing stakeholder engagement and information sharing. The Committee’s recommendations are listed at the end of the Government Response for ease of reference.

Further Research and Investigation into Possible Links Between EMF RF Exposure and Cancer (Recommendations 1, 10, and 11)

To date, thousands of scientific studies have been carried out globally to evaluate the safety of RF EMF. The results from these and ongoing studies have informed the development of Canadian and international human exposure limits. Human exposure limits to RF EMF have existed in Canada and internationally for over 30 years. These exposure limits have taken into account the latest scientific information on established health effects of RF EMF and have incorporated large safety margins for the avoidance of such health effects. Health Canada's recommended human exposure limits are outlined in a document entitled “Safety Code 6 Limits of human exposure to radiofrequency electromagnetic fields in the frequency range 3 kHz to 300 GHz” (Safety Code 6). While the human exposure limits in Safety Code 6 were initially developed for, and applied by, federally-regulated employers, some of the exposure limits in the Code have since been referenced by other federal departments and non-federal jurisdictions. In particular, Innovation, Science and Economic Development Canada (ISEDC) requires compliance with Safety Code 6 as part of its technical standards for radio apparatus. Furthermore, compliance with the relevant Safety Code 6 limits, by all operators of antennas, is required through licensing requirements under the Radiocommunications Act . The exposure limits in Safety Code 6 have been updated periodically since they were first developed in 1979, with updates occurring in 1991, 1999, 2009 and, most recently, in 2015.

In recent years, the issue of a possible association between mobile phone use and brain cancer has been a topic of public and scientific concern. To address this issue, in 2011 the International Agency for Research on Cancer convened an Expert Panel to review the scientific evidence pertaining to the possible cancer causing ability of RF EMF. A Health Canada scientist was among the experts conducting the review. Upon considering the available evidence, the IARC Expert Panel classified radiofrequency EMF as "possibly carcinogenic to humans" (Class 2B), based on an increased risk for glioma (a type of brain cancer) associated with long-term heavy cell phone use in some studies, for some statistical comparisons. However, the vast majority of studies have not found similar results. The IARC classification of RF energy reflects the fact that this limited evidence exists and cannot rule out RF energy as a possible risk factor for cancer.

Health Canada supports the IARC Class 2B designation and agrees the evidence of a possible link between RF EMF and cancer risk is far from conclusive and that more research is needed to clarify this "possible" link. Given the uncertainty associated with long-term heavy use of cell phones Health Canada issued precautionary advice, consistent with IARC’s advice, to cell phone users informing them of practical ways they can reduce their exposure to RF EMF from cell phones. 

As the Government of Canada recognises more research is needed, scientists interested in this issue are encouraged to make use of current Government funding programs for health research. The Government of Canada funds scientific research on health related questions primarily through the Canadian Institutes for Health Research (CIHR). Canadian scientists from eligible research institutions receive support from CIHR through both targeted and investigator-initiated funding programs. Through its investigator-initiated funding programs, CIHR supports research in areas related to electromagnetic frequencies and health. Examples of this research include work led by researchers at Western University in London, Ontario who have led two major, multidisciplinary research investigations into the impact of low- and high-level, time-varying electromagnetic fields (EMFs) on brain activity and physical behaviour.

Through CIHR, the Government of Canada is also working with its partners to avoid unnecessary duplication of effort and to coordinate research on an international level. For example, CIHR has partnered with the Canadian Wireless Telecommunications Association to fund Canadian participation in the MOBI-Kids study. This research, led through the University of Ottawa in collaboration with the British Columbia Cancer Agency and Cancer Care Ontario, is an international, multi-centric, case-controlled study which aims to assess the potential associations between use of communication devices and other environmental risk factors with brain tumors in children and youth. Information on the MOBI-KIDS programme can be found at http://www.crealradiation.com/index.php/en/mobi-kids-home.

The Government of Canada is also involved in supporting research efforts on EMF outside of CIHR.

  • Health Canada continues to monitor the scientific literature and has conducted its own research on the biological effects of RF energy. This research has increased the scientific knowledge regarding the intensity of RF energy in our environment, the possible biological/health effects of RF energy and has helped to establish the human exposure threshold where potentially adverse health effects may occur. This important information, along with other Canadian and international studies, form the basis for establishing safety standards for RF energy that protects the health of Canadians. Information on Health Canada research in this area is available on the Health Canada website: http://www.hc-sc.gc.ca/ewh-semt/radiation/cons/radiofreq/research-recherche-eng.php.

  • The Natural Sciences and Engineering Research Council of Canada (NSERC) also supports research on EMF. Since 2002, the NSERC Industrial Research Chair in Risk Science has conducted a broad program of research and training in risk science, particularly with respect to the assessment and management of population health risks associated with technological developments. NSERC is supporting work underway at Laurentian University in Sudbury on the effects of EMF on specific biological signals. This research project aims to determine whether certain EMF can inhibit cancer cell growth.

Comprehensive reviews of the scientific literature relating to RF fields have been carried out by scientists and expert panels under the auspices of highly recognized international bodies including the European Union’s Scientific Committee on Emerging and Newly Identified Health Risks and the International Committee on Non-Ionizing Radiation Protection. The approach, commonly referred to as a scientific monograph, is generally conducted by international bodies requiring the participation of many scientific experts (40+) and many years of effort. Recent similar efforts have taken place by IARC as well as the WHO. Health Canada has been taking part in the International EMF Project, coordinated by the WHO. The goals of this project are to verify reported biological effects from exposure to EMFs and to characterize any associated health risks to humans. The WHO is committed to conduct a formal risk assessment of all studied health outcomes from RF field exposure by 2017.

Health Canada’s participation on these bodies allows the Department to leverage these large-scale and highly resourced international efforts which are widely recognized as comprehensive, and more detailed, than any review from a single jurisdiction could be. In addition to participating in the international monograph exercises, Health Canada officials carry out an ongoing review of emerging scientific studies in this area. If new scientific evidence were to demonstrate that exposure to RF energy below levels found in Safety Code 6 from wireless technologies is a concern, the Government would take appropriate action to help protect the health and safety of Canadians.

With respect to the recommendations to work with partners in the examination of cancer data collection methods and information on wireless device use and cancer, Statistics Canada has collected cancer data broadly since 1969, initially with the National Cancer Incidence Reporting System and currently with the Canadian Cancer Registry (CCR) established in 1992. The CCR is a collaborative effort between Statistics Canada and the 13 provincial and territorial cancer registries to create a single database to report annually on cancer incidence and survival at the national and jurisdictional level.

The CCR contains demographic data and information related to the characteristics of the cancer (such as primary site and morphology), on each cancer case diagnosed in Canada, however it does not include any information on health behaviours or environmental exposures, such as diet, tobacco use, or the use of wireless devices. As the research community continues to study the question of wireless device use and cancer, Statistics Canada will, with the involvement of its partners, and the research community, assess the suitability of the cancer incidence data collected within the CCR as a source of information for the research community. Activities in early planning stages are underway which may lead to the addition of socio demographic information and information about treatment in the future. 

Greater Understanding and Management of Electromagnetic-hypersensitivity (EHS) (Recommendations 2, 3, 4, and 5)

Health Canada acknowledges that some people have reported an array of health symptoms that they attribute to exposure to EMF. At present, the symptoms attributed to EMF exposure have been termed idiopathic environmental intolerance (IEI-EMF) by the WHO, where “idiopathic” refers to unknown causes. This means that while the symptoms attributed by some persons to EHS are real, the scientific evidence provides strong support that these health effects are not associated with EMF exposure. Other recent reviews have been carried out by international bodies including the European Commission (2015), the Swedish Radiation Safety Authority (2015), Public Health England (2012) and the Australian Radiation Protection and Nuclear Safety Agency (2015); all reaching similar conclusions. Domestically, in its 2014 review of Safety Code 6 the Royal Society of Canada found, “taken together, research in the past ten years does not provide firm evidence for the hypothesis that people with IEI-EMF can perceive RF energy levels below the limits in Safety Code 6 or that there is a causal link between exposure to RF and their symptoms”. 

Health Canada agrees that the Government of Canada should continue to provide accommodation measures for individuals suffering from disabilities, as required under the Canadian Human Rights Act and has shared a copy of the Committee’s report with officials at the Canadian Human Rights Commission for their consideration as appropriate.

As outlined above, the Government of Canada supports research in areas related to EMF and health through CIHR’s investigator-initiated research programs. We encourage scientists interested in conducting further research studies in this area to make use of CIHR funding opportunities (https://www.researchnet-recherchenet.ca/rnr16/search.do?fodAgency=CIHR&fodLanguage=E&all=1&search=true&org=CIHR&sort=program&masterList=true&view=currentOpps).

The Canadian Community Health Survey (CCHS) is a cross-sectional survey that collects information related to health status, health care utilization and health determinants for the Canadian population. New questions related to EHS could only be included in the CCHS once they meet Statistics Canada quality criteria for content. In the case of EHS, the lack of a clear etiology and definition by the research community (standard and accepted definition related to an accepted medical disorder) would limit the feasibility of interpreting and reporting on any data collected.

In response to the Committee’s recommendation for updates to clinical guidelines and continuing education materials for health care providers, Health Canada has shared the report of the Committee with the Canadian Medical Association, the Royal College of Physicians and Surgeons, the College of Family Physicians, and the WHO for their consideration of recommendations relating to their respective mandates as appropriate.

Protecting the Most Vulnerable, Enhancing Stakeholder Engagement and Information Sharing (Recommendations 6, 7, 8, 9, and 12) 

It is Health Canada’s position, and that of the Expert Panel of the Royal Society of Canada, that current measures on RF EMF protect our most vulnerable. Safety Code 6 human exposure limits, established by Health Canada, are designed to provide protection for all age groups, including infants and children, on a continuous basis (24 hours a day/seven days a week). This means that if someone, including a small child, were to be exposed to RF energy from multiple sources for 24 hours a day, 365 days a year, within the Safety Code 6 limits, there would be no adverse health effects. Based on a thorough review of all available data, it is Health Canada’s position that there are no established adverse health effects at levels below the limits outlined in Safety Code 6. This conclusion is similar to that arrived at by the International Commission on Non-Ionizing Radiation Protection (ICNIRP), the European Commission’s Scientific Committee on Emerging and Newly Identified Health Risks, and the WHO. The approach applied in Safety Code 6 (2015), which specifically incorporated human exposure limits based upon child body sizes, was recently recommended by the French Agency for Food, Environment and Occupational Health and Safety (ANSES) in their recent review entitled "Exposition aux radiofréquences et santé des enfants" (https://www.anses.fr/fr/system/files/AP2012SA0091Ra.pdf).

Health Canada’s latest process to revise Safety Code 6 was the most comprehensive, inclusive and transparent process to date.  Health Canada published its proposed 2014 revisions to Safety Code 6 for public consultation between May 16 and July 15, 2014 and welcomed feedback from interested Canadians and stakeholders.  The revised Safety Code 6, which was published in 2015, as well as the summary of consultation feedback is available on Health Canada’s website. The revised document also underwent an extensive independent peer review by an Expert Panel of the Royal Society of Canada; a process which further considered stakeholder feedback. Overall the Royal Society’s review of Safety Code 6 was favourable and supported the science based conclusions that the basic restrictions in the Safety Code 6 provided adequate protection. Based on evidence which emerged after Health Canada submitted Safety Code 6 for review, the Society did recommend slightly more restrictive reference levels in some frequency ranges to ensure larger safety margins for all Canadians, including newborn infants and children.  Health Canada accepted the recommendation and adjusted Safety Code 6 accordingly.

As outlined above there is ongoing significant international work on RF EMF and its impact on our health. The collective expertise of the international scientific community working for these bodies, which include Health Canada scientists, is a valuable world-class resource. Given the Government frequently makes use of international standards in other areas, Health Canada will, over the medium to long term, examine how it can better leverage international scientific expertise in its work on RF EMF.

When establishing Safety Code 6, Health Canada incorporated several tiers of precaution into the human exposure limits. These included conservative thresholds for the occurrence of adverse effects, extreme worst-case situations for body size and orientation in relation to the RF fields, and additional safety margins. Since these conservative approaches are cumulative, i.e., stacked upon each other, Safety Code 6 provides very large margins of safety against the occurrence of all established adverse health effects associated with RF field exposure. In addition, Health Canada maintains messaging on its website that reminds cell phone users that they can take practical measures to reduce their RF exposure by limiting the length of cell phone calls, using “hands-free” devices and replacing cell phone calls with text messages. This messaging also encourages parents to take these measures to reduce their children’s RF exposure from cell phones in acknowledgement that children are typically more sensitive to a variety of environmental agents.

The limits within Safety Code 6 are designed to provide protection for all age groups, including infants and children, on a continuous basis. Under the Canada Consumer Product Safety Act , it is prohibited to advertise a consumer product, including consumer products that are radiation emitting devices, if the advertisement in question creates an erroneous impression regarding the device’s safety, or if the product itself is a danger to human health or safety. Prohibitions respecting the advertising of radiation emitting devices are also set out in the Radiation Emitting Devices Act . Health Canada has shared the report of the Committee and its recommendations with both Advertising Standards Canada and the Canadian Radio-television and Telecommunications Commission (CRTC) for their consideration as appropriate.

Consumer complaints concerning products, such as cell phones, can be directed to Health Canada using the web-based system developed under the Canada Consumer Product Safety Act and accessible through the Healthy Canadians website http://www.healthycanadians.gc.ca/report-signalez/index-eng.php.  The system identifies hazards that can then be addressed by appropriate experts within Health Canada and ISEDC.

Health Canada, other leading health agencies, and the WHO, have concluded that, to date, there is no convincing scientific evidence linking adverse symptoms to levels below existing RF exposure limits. As such the feasibility and utility of a dedicated adverse reporting system specific for RF devices, similar to the reporting of adverse drug reactions, is limited. Consequently, Health Canada does not support the establishment of an adverse reporting process specifically for RF exposure, but will continue to monitor the international scientific literature and incident reports arising from existing web-based reporting systems, and promote information sharing amongst all levels of government. 

In response to HESA’s recommendations, Health Canada will communicate more effectively on how it contributes to international organizations (WHO, IARC, etc.), other governments, and non-governmental organisations in managing and monitoring scientific research on RF impact on human health. It will further elaborate on its process to review and consider emerging scientific literature published subsequent to these international exercises.

Health Canada maintains web-based information to inform the public on exposure to RF energy. Components include the “Healthy Canadians” web-based series of publications, which address issues such as the safety of cell phones and cell phone towers, electric and magnetic fields at extremely low frequencies, electromagnetic hypersensitivity, Wi Fi equipment and smart meters (http://healthycanadians.gc.ca/drugs-products-medicaments-produits/consumer-consommation/home-maison/cell-eng.php?_ga=1.256297484.608447883.1437502675). Health Canada will seek opportunities to strengthen public communications as appropriate.

Health Canada has previously provided timely scientific information and messaging on EMF and health to federal, provincial, and territorial partners, including through the Pan Canadian Public Health Network. The Department will maintain this practice and its ongoing relationship with its FPT partners in an effort to support regional efforts and decision-making in this area.   

In response to the Committee’s recommendation that Health Canada ensures the openness and transparency of its processes for the review of Safety Code 6, the Department will consider various strategies for further supporting transparency in the process including implementing an enhanced process for the systematic review and documentation of scientific literature related to RF EMF exposure and health.