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Anthony Miller
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Anthony Miller
2015-04-23 15:34
Mr. Chair, members of the committee, thank you very much for giving me the opportunity to present on Health Canada's review of the evidence for Safety Code 6, which I believe has led to unsafe conclusions.
I am a physician and epidemiologist specializing in cancer etiology, prevention, and screening. I have performed research on ionizing radiation and cancer, electromagnetic fields and cancer, and other aspects of cancer causation. I have served on many committees assessing the carcinogenicity of various exposures, including working groups of the International Agency for Research on Cancer, commonly known as IARC, of which Canada is a member. I was the first Canadian member of their scientific council.
I was a visiting senior scientist in the monographs program in IARC in September 2011 until January 2012, where as part of my duties I reviewed the scientific literature that was used by a working group to designate radio frequency fields as a class 2B carcinogen, that is, a possible carcinogen. I was also one of the peer reviewers invited by the Royal Society of Canada to review the draft report of the Royal Society panel on Safety Code 6.
I have a number of concerns over the documents that have recently been released by Health Canada on Safety Code 6 and the document called “Rationale”. What Health Canada has said in its latest iteration of Safety Code 6 is that it should be distinguished from some municipal and national guidelines that are based on socio-political considerations. I find that a strange statement because it seems to provide no room for emerging evidence on health hazards, which surely should be considered if the safety of humans is the objective.
Since the IARC review, which identified radio frequency fields as a possible human carcinogen, there had been a number of studies that have been reported. In my view—and that of a number of colleagues who've written a couple of papers with me on this issue, one of whom will present to you next week—these studies, we believe, reinforce the evidence that radio frequency fields are not just a possible human carcinogen but a probable human carcinogen, putting it in the category 2A. It would be impossible to ignore such a hazard in regulatory approaches.
One of the most important was a study in France, a large case-controlled study, which found a doubling of risk of glioma, the most malignant form of brain tumour, after two years of exposure to cellphones. After five years it was five times the risk. They also identified the fact that in those who lived in urban environments, where there are probably a number of other carcinogens that could impact upon brain tumours, the risk was even higher.
That brings us back to Safety Code 6 and the document that Health Canada contracted to produce a review of the evidence. This was the document produced by the Royal Society panel. I feel that panel was conflicted. As you probably know, the chair changed and the panel had insufficient expertise in epidemiology. My friend, Paul Demers, was called in to be chair of that panel. I believe he presented to you fairly recently. I feel he was put in an impossible situation.
If you read that document carefully, it says that the panel did not have adequate time to do a full review of the data, they therefore relied on reviews of other people and they did not do a detailed evaluation of the studies. That led them, I believe, to false conclusions.
It's important to recognize that there are no safe levels of exposure to human carcinogens. Although risk increases with increasing intensity of exposure, and for many carcinogens, such as tobacco smoke, even more with increasing duration of exposure, the only way to avoid the carcinogenic risk is to avoid exposure altogether. This is why we tend to ban carcinogens from the environment. Asbestos is one particular example of why much effort is taken to get people, particularly young people, not to smoke. Further, we now recognize that people vary in their genetic makeup, and that certain genes can make some people more susceptible than others to the effect of carcinogens. It is those who are susceptible that safety codes should be designed to protect.
As an epidemiologist who has done a great deal of work on breast cancer, one of the most concerning factors that have come to light is a series of case reports, starting with some reports from California and recently with the identification of a similar case in Saskatchewan. In all, there are now seven case reports of women who developed unusual breast cancers in the exact position where they kept cellphones in their bras. These are unusual tumours. They're multifocal, which means they occur in several places. They seem to mirror where the cellphone was being kept. The radiation from the cellphone seems to have increased in these women the risk, which they presumably already had, of developing breast cancer. They were all relatively young women. This is a most unusual occurrence that must concern us greatly.
We have brain cancers and parotid gland tumours, which are tumours of the salivary gland. There have been several instances of people who have developed this. In Israel recently a study identified increasing risk of these cancers, particularly with increasing exposure.
Given the long natural history of cancer and the fact that human populations have not been exposed for a sufficient length of time to exclude a carcinogenic effect, it is in my view extremely important to adopt a precautionary approach to the exposure of humans, particularly children, to radio frequency fields. We should note that an individual, if appropriately informed, can reduce their exposure to radio frequency fields from devices that use Wi-Fi, but in the case of cell towers and smart meters, the exposure they receive is outside their control. Then, with the people who manufacture these devices and those who promote Wi-Fi in all sorts of instances, we're reaching a situation where homes are being saturated with radio frequency fields.
It will be very difficult to prove conclusively an effect. Spread over a large population, if the normal occurrence is relatively rare—and it is relatively rare for brain tumours to occur—even if you double the risk, triple the risk, or even quadruple the risk, it will be difficult to identify that precisely. We need to do these studies.
In the meantime, to avoid a potential epidemic of cancer caused by radio frequency fields from Wi-Fi and other devices, we should strengthen the codes that are meant to protect the public. In my view, Health Canada has not done an adequate job. Safety Code 6, in its current iteration, needs to be re-revised.
I thank you, Mr. Chairman.
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.
Paul Demers
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Paul Demers
2015-03-24 15:53
Thank you, Mr. Chair and members of the committee, for inviting me here today. I know I've been asked to come here today because I chaired the expert panel of the Royal Society of Canada on Safety Code 6. But I thought I'd start by saying a few other things about my background.
I'm the director of the Occupational Cancer Research Centre, which is based in Cancer Care Ontario, a provincial agency that is also funded by the Ontario Ministry of Labour and the Canadian Cancer Society. I'm also a member of the faculty of the schools of public health of the University of Toronto and the University of British Columbia.
I am an epidemiologist, so I study impacts of different types of health effects upon populations of people, but my primary area of research is on the risk of cancer associated with workplace chemicals, dust, and radiation, although I have done research on a number of other diseases as well as on environmental exposures. However, I want to state that, unlike Dr. Prato, I'm not an expert specifically in the area of electromagnetic fields and have never actually done research on radio frequency radiation.
As you know, at the request of Health Canada the Royal Society convened an extra panel to conduct a review of the 2013 draft of Safety Code 6. I was asked to chair that panel because I had no conflicts of interest and because of my expertise in cancer epidemiology, which was identified as one of the areas for which they wanted expertise on the panel.
I was also asked because of my experience sitting on similar panels for the International Agency for Research on Cancer, the U.S. national toxicology program, the U.S. Institute of Medicine, which is part of the National Academy of Sciences, and the Council of Canadian Academies, the latter two being fairly similar to the Royal Society of Canada in the way they operate.
I should also mention, although you may be aware of this already, that I was the second chair of the panel. The first panel resigned because of a perceived conflict of interest, and I took over as chair of the panel about midway through. But I also want to state that I'm here as individual and am not representing the Royal Society of Canada or any other organization at this point.
The panel was presented with five specific questions, and I'm going to over very briefly our responses to those five questions. Overall, they were all dealing with whether or not there were any established health effects at levels below those recommended by Safety Code 6 and related types of questions.
To answer these questions, we did a review of recently published studies in the area on a wide range of different types of health effects. We also looked at many of the international reviews, which I think have already been mentioned here today. These are conducted on a pretty regular basis by many agencies around the world.
Because we were asked to look in particular at established health effects, we defined an established adverse health effect as something that has been seen consistently or been observed consistently in multiple studies with a strong methodology. So we had a fairly flexible definition, but still it required an effect's being observed in not just a single study.
Before I get into the questions—because I'm actually going to read out the questions we were given—I want to explain two different terms that are used quite a bit in those questions, namely the definition of what basic restrictions are and what reference levels are.
Basic restrictions in Safety Code 6 are things that happen within the body, either heating or induced fields within the bodies, or things like those. Many of the actual limits are set based upon that. Because these are not easily measured, the code also uses reference levels, which are things you can measure outside of the body using a meter. They are much easier for regulatory purposes. You will often see that the questions are phrased in terms of these basic restrictions and reference levels.
Our first question was, do the basic restrictions specified in Safety Code 6 provide adequate protection for both workers and the general population from established adverse health effects of radio frequency fields? Our conclusion was that yes, they provided that protection. Specifically, Safety Code 6 was designed to protect against two kinds of established health effects, thermal effects and peripheral nerve stimulation. The margins of safety, we concluded, appeared to be quite protective. For peripheral nerve stimulation, it was a safety factor of five for the workplace or controlled environments, and a 10-fold factor for uncontrolled environments, which are closer to what you would experience in the general public. For thermal effects, the safety factor was 10-fold for workplaces and 50-fold for the general public.
The second question that we were given was, are there any other established adverse health effects occurring at exposure levels below the basic restrictions on Safety Code 6 that should be considered in revising the code? Our conclusion to that question was no. The panel reviewed the evidence for a wide variety of health effects, including cancer, cognitive and neurologic effects, male and female reproductive effects, development effects, cardiac function, heart rate variability, electromagnetic hypersensitivity, and adverse effects in susceptible areas of the eye. Although research in many of these areas—important research, I think—continues, we were unable to identify any adverse health effects occurring at levels below those allowed by Safety Code 6.
Our third question related specifically to the eye: Is there sufficient scientific evidence upon which to establish separate basic restrictions or recommendations for the eye? We concluded that no there wasn't sufficient evidence. Recent studies do not show adverse health effects in susceptible regions of the eye at exposure levels below those proposed by Safety Code 6 for the head, neck, and trunk. Therefore we recommended that it not contain separate basic restrictions for the eye.
The fourth question was perhaps a bit more complex: Do the reference levels established in Safety Code 6 provide adequate protection against exceeding the basic restrictions? That is, do the levels that are proposed as limits for things you can measure outside the body actually protect against the target health effects the code is trying to prevent within the body? Our conclusion was that for most frequencies, yes, reference levels were adequate, but that there were some regions where compliance with the reference levels may not ensure compliance with the basic restrictions. We recommended that the proposed reference levels in Safety Code 6 be reviewed by Health Canada to make them somewhat more restrictive in some frequency ranges to ensure a larger safety margin for Canadians, including newborn infants and children.
This recommendation took into account recent studies that we call dosimetry studies, at least one of which was published after Health Canada produced the proposed Safety Code 6.
Our fifth question was, should additional precautionary measures be introduced into Safety Code 6 exposure limits? I'll state that although there was a range of opinions on the panel regarding precautionary efforts, overall the panel believed that Safety Code 6 was well-designed to avoid established health effects; we did not have any science-based recommendations for precautionary measures to lower the limits. I'll say that it was for the reasons that I think Dr. Prato explained quite well, which is that we couldn't, at least in looking at the study, say that the evidence tells us that we should lower it it in such a fashion. However, we did recommend a number of other measures that can and should be taken by Health Canada.
I'll read some of them here now.
First was to investigate the problems of individuals with what's called electromagnetic hypersensitivity—it goes by other names as well, IEI-EMF, and things like that—with the aim of understanding their health conditions and finding ways to provide effective treatment.
Second was to develop a procedure for the public to report suspected disease clusters and a protocol for investigating them.
Third was to expand Health Canada's risk communication strategy to address consumer needs for more information around radio frequency radiation.
Fourth was to identify additional practical measures that Canadians can take to reduce their own exposure.
These recommendations are really in response to the public input that we received as part of the panel. We also had a number of different research recommendations. In particular, if one has the chance to read the report, you'll notice that each section on a particular health effect usually ends by basically pointing out that more research is needed on that health effect.
A few of the specific ones are that Health Canada should aggressively pursue research aimed at clarifying the radio frequency radiation cancer issue, which would allow the government to develop protective measures if the risk were substantiated; and that Health Canada should pursue research to expand our current understanding of possible adverse health effects of exposure to radio frequency radiation at levels below those allowed by Safety Code 6.
The response to the panel's report from Health Canada—
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