Interventions in Committee
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Frank Clegg
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Frank Clegg
2015-04-23 15:45
Mr. Chair and committee members, I'd like to thank you for the invitation to speak with you this afternoon and for deciding to invest committee time on Safety Code 6.
When I ran the Canadian operations for Microsoft, I learned that it is critical to focus on process. Today, as a board member for Indigo Books and Music, my role has shifted more towards governance and oversight. In both roles, process is critical to success. Government is the largest corporation of all, so process is of paramount importance. As someone who regularly examines success and failure, I believe I can explain why the Safety Code 6 process is a failure by all metrics and has left Canadians unprotected.
There is a book written by Nassim Taleb called The Black Swan, a focus on very low-probability, high-impact events that aren't supposed to happen. Oil spills, train derailments, and airplane crashes are some of the events in this category. Taleb calls these “black swan” events.
If one decides that all swans are white and refuses evidence of black swans, then one will conclude that all swans are white. Black swans are rare, but they do exist. Unfortunately, experts convinced themselves that these events had zero probability. They did not plan appropriately and people died.
The American Academy of Environmental Medicine is an international organization of physicians and scientists that has predicted, among other things, the rise in multiple chemical sensitivity, which is now protected in many public policies. Regarding the unprecedented increase in wireless devices, the academy forecasts “a widespread public health hazard that the medical system is not yet prepared to address”.
I believe Health Canada's analysis focuses on identifying and counting white swans, while ignoring black swan evidence. Health Canada's representative informed this committee on March 24:
...some of these studies report biological or adverse health effects of RF fields at levels below the limits in Safety Code 6, I want to emphasize that these studies are in the minority and they do not represent the prevailing line of scientific evidence in this area.
In other words, black swans exist.
In your handout—I don't know if you have it, as we put it in for translation—is a document entitled “Analysis of 140 Studies Submitted by Canadians for Safe Technology (C4ST) During the Public Comment Period on Safety Code 6”. A chart in that document shows that Health Canada accepts that there are in fact 36 studies all passing Health Canada's quality criteria showing harm at levels below Safety Code 6.
As a Canadian, I find this confusing. As an executive, I find it inexcusable.
Of the 36 studies Health Canada deemed satisfactory, cancer is linked in six of them. In 13 of them, the brain and/or nervous system is disrupted. In 16 studies, Health Canada admits that biochemical disruption occurs. Finally, seven high-level scientific studies indicate an effect on intellectual development and/or learning behaviour. All of these studies show impacts with radiation below Safety Code 6 limits. How was this black swan evidence evaluated?
In our two-year investigation, C4ST has determined that Health Canada doesn't even have the proper software required to access, summarize, and analyze the large number of relevant studies. If our group of learned and qualified volunteers can uncover 140 studies, how many more are being missed or ignored?
Health Canada references its weight-of-evidence approach. It is unclear how many studies you need to outweigh 36 studies that show harm, especially to children. I just can't fathom why Health Canada is not highlighting these studies and prioritizing their implications. Despite requests to publish the weight-of-evidence criteria as per international standards, Health Canada refuses to do so. Even the recent 2015 rationale document does not provide this critical information.
Health Canada dismisses scientific evidence unless it shows harm where the microwave levels are strong enough to heat your skin. The notion that microwaves are not harmful unless they heat your skin is decades out of date. The core premise of this white swan dates back to Einstein's theory that non-ionizing radiation cannot cause harm, or if it does, it must heat tissue to do that. Albert Einstein passed away the same year Steve Jobs was born. To think that science has not evolved since then is classic white swan thinking. It's part of a process predetermined to fail.
Health Canada says on its website today that there is no chance that Wi-Fi or cellphones can harm you because it has studied all the science, but when pressed under oath, Health Canada officials give a more fulsome answer. In Quebec Superior Court in September 2013, Health Canada senior scientist James McNamee admitted that Health Canada only assesses risk based on the thermal effect, i.e., the heating of tissue.
Unfortunately, Canada has not invested the necessary time nor had the balanced opinion of experts necessary to undertake a proper review. Our research has uncovered that the Health Canada author of Safety Code 6 has published papers demonstrating his bias towards this topic.
In a few hours over three days, this health committee has spent more time speaking with scientific experts who believe there is harm from wireless radiation below Safety Code 6 than all of Health Canada combined. You can't find black swans when you don't talk to the experts who've identified them.
There is a fundamental business rule: you can't manage what you don't measure. It is clear that Health Canada not only doesn't follow that rule but even resists it. A memo obtained under access to information to the Minister of Health in March of 2012 revealed that Health Canada “does not support the recommendation to establish an adverse reaction reporting process specifically for RF exposures”. The memo goes on to state that “consumer complaints...may be directed to...the web-based system...under the...Canada Consumer Product Safety Act”. This is an inadequate solution and, I believe, a missed opportunity.
I refer you to the C4ST fact sheet. I think you have it. I'd like to highlight three examples from that fact sheet: Health Canada's Safety Code 6 is among the countries with the worst guidelines in the world; Canada has fallen behind countries such as France, Taiwan, and Belgium in protecting Canadians; and finally, Health Canada wasted over $100,000 of taxpayers' money, as the Royal Society report is not an independent review.
Health Canada also states that Safety Code 6 is a guideline and that other organizations at the provincial and local levels of government are free to implement lower levels as they see fit; however, that's not the reality of what happens. We have witnessed school boards, power and water utilities, Industry Canada, and manufacturers depending on Health Canada's analysis, and frankly, abdicating to it. They don't perform their own analysis.
Safer solutions exist. There are several situations in Canada regarding cell towers where the proponents have voluntarily offered to restrict radiation exposure, in some cases to thousands of times less than Safety Code 6. There is a solution in Iowa for smart meters that use a wired meter that provides a safer, more secure solution at a lower cost.
Given that our track record in North America is not successful regarding such products as tobacco, asbestos, BPA, thalidomide, DDT, urea-formaldahyde insulation, and many others, use of the precautionary principle of prudent avoidance should be recommended until the science proves beyond reasonable doubt that there is no potential for harm.
For the last three years, science has published a new study every month that shows irreparable harm at levels below Safety Code 6. That is why we're asking the committee to take three decisive steps.
First, conduct a national campaign to educate Canadians about methods to minimize exposure to RF radiation, ban Wi-Fi in day care centres and preschools, and ban the marketing of wireless devices to children.
Second, protect individuals who are sensitive to RF radiation by accommodating them with safer levels of wireless exposure in federal workplaces and federal areas of responsibility.
Third, and finally, create an adverse reporting system for Canadians and a publicly available database to collect improved data regarding potential links between health effects and exposure to RF radiation.
Parallel to the above, recommend that Health Canada conduct a comprehensive systematic review, subject to international standards, regarding the potential harmfulness of RF radiation to human health, with a scientific review panel that is balanced in opinion. It was a textbook case of black swan thinking that has led to this failure of Safety Code 6.
In conclusion, C4ST volunteers found 36 black swans that Health Canada agrees are high quality. How many would be available if Health Canada sincerely looked? Better yet, how many black swans will it take before Health Canada takes serious actions? Thank you very much.
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