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Frank Clegg
View Frank Clegg Profile
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.
View Christine Moore Profile
NDP (QC)
We know that provincial health care is paying more and more for infertility treatments. Should we, in your opinion, pay particular attention to this issue if we want to avoid getting an enormous bill later? Often, people try to have a child for a long time before realizing that they have these problems. If someone has been carrying a cell phone in his pocket for 20 years, then it may be difficult to help with related issues later. Should this be of particular concern to us, in your opinion?
Frank Clegg
View Frank Clegg Profile
Frank Clegg
2015-04-23 16:14
One of our recommendations is for Health Canada to raise an awareness campaign. Part of that awareness campaign should be telling young men to keep the phone out of their pants' pockets, because that's where men keep their phones. Young men keep their phones in their pockets. That's why we were calling for a recommendation to have Health Canada educate people to be aware that there is a potential risk and prevent it.
View David Wilks Profile
CPC (BC)
Thanks, Chair.
Thank you to the witnesses for being here. I'll share my time with Mr. Richards, because he has to leave here after the first hour, I believe.
You perked my interest when you said police officers and radar because I did that for a year and a half.
Professor Miller, you mentioned in your opening remarks that an opportunity to provide greater safety to the public has been missed. You did explain a bit about it, but I wonder if you could articulate a little more on what we've missed and what we could move forward with in respect to recommendations to Health Canada and to the minister.
Anthony Miller
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Anthony Miller
2015-04-23 16:15
When I think about Health Canada, I'm not saying this committee has missed. What Health Canada has missed is a proper scientific review of the data that would convince them—and I don't understand why they haven't been convinced—that the limits they have placed in their advisory limits are not sufficiently safe to protect the population. That's why I believe an opportunity to protect the population, and potentially to prevent a major cancer problem in the future, has been missed by Health Canada.
View Hedy Fry Profile
Lib. (BC)
This is like déjà vu. I think you asked a very important question, Dr. Havas. I don't understand. Inherent, for instance, in the medical ethos is to first do no harm, so the primary thing for a physician is the precautionary principle unless you see that the benefits outweigh the risks and you are prepared to do some harm in order to divert worse harm.
I've been listening to this so I called up my son and my daughter-in-law and I said, “Hey, you guys have a wireless baby monitor on my granddaughter's crib. I'm hearing this stuff and I think maybe you should take precautions and get a plug-in monitor or find a way to turn it on only when you need to”.
They said to me, “Oh, for God's sake, that is such a bunch of hokey stuff. The guidelines are clear, blah, blah, blah”, and of course I was almost accused of crying wolf.
If I couldn't convince my children that this is not reasonable and fair.... I think you said that it was 50 years before we got anybody to understand, in spite of evidence, that cigarettes caused cancer; and in the case of acid rain, it was 20 years. Surely to goodness we have learned by now that we shouldn't be taking that long. We need to see the harm that not acting on evidence sooner does.
Given that those blocking this the most are in industry themselves, and the fact that, let's be honest, governments have to balance economic growth and development and progress against harm to the greater good, and given that there is almost this conflict of interest between how governments currently operate and how governments could operate to protect people, how can we convince the public, which is completely addicted to Wi-Fi and to wireless devices, when they don't know anything else?
I'm addicted. I can't put away my stupid BlackBerry, so how do we convince people, because public awareness, obviously, as Frank said, must be a part of the recommendations? How do you put forward a public awareness program that will actually reach people and sink in without people saying, “Oh my God, everybody is being so hysterical about this”?
Frank Clegg
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Frank Clegg
2015-04-23 16:25
I would make two comments, Dr. Fry.
I would say that people are smart, and when they have the right information, they act appropriately and they act responsibly, particularly parents with newborns.
What I've heard though, hundreds of times now, is that it must be okay if Health Canada says it's safe. They don't understand that it takes time for this information to be digested. As Dr. Miller said, we are befuddled as to why Health Canada isn't being more active. If the health authority in Canada, which is Health Canada, came out with very clear statements that said there is proof that there could be harm, so we should be careful and take a precautionary approach, I think you would see the majority of Canadians change what they do.
You also made a comment about industry. I have spent my life in industry. We go out and work hard to provide technology that is cheaper, faster, better. That's the way we work.
View Hedy Fry Profile
Lib. (BC)
I do think, however, there's this inherent conflict and problem because Industry Canada should be looking at how we can make sure that industry is progressive, is functioning, and we have economic development going on in the country. But that is not Health Canada's mandate.
View Hedy Fry Profile
Lib. (BC)
Health Canada's mandate is very clear. It is supposed to protect the health and safety of Canadians.
View Hedy Fry Profile
Lib. (BC)
Surely to goodness I think we in this committee here, having heard the things we heard, and having learned—because I'm long in the tooth—from the things we had been fighting against, for such a long time, that cause great harm and eventually everyone.... Now we have seatbelts in legislation, and all of those kinds of things that protect people. It was a long fight.
For me, the idea that we should let Health Canada believe that it has to be true to its own mandate, which is the protection of Canadians, should be the overriding concern of this committee. I can tell you now it's something that I've taken seriously and it's something I'm going to do something about. I've lived through this stuff, as a physician and in all of my years as an environmental advocate, etc., and we have to do better than we currently do now.
I want to thank you for your presentation, actually, because it's clear and it's scientifically based. The evidence you talked about is something that we need to call for, which is a new review. Given that other countries have set the tone, France and Israel, and other countries, I think this committee should hear you very clearly. I know some of us are.
View Cathy McLeod Profile
CPC (BC)
Thank you.
I'd like to thank the witnesses for their presentations.
Certainly, as I mentioned before, I was on the committee that originally set that process in place in terms of the work done by the Royal Society. Certainly the intention of the committee was to have something that was very solid in terms of its response to that issue.
I understand Canada is also currently very active with the WHO in terms of a massive undertaking. Is maybe that the better place to be really looking at the scientific reviews around this issue?
Could someone speak to the WHO process? It seems sometimes like we have all these different countries that spend a lot of time, money, and energy, and keep reinventing the wheel. What about this international collaboration piece and is that the better mechanism?
Frank Clegg
View Frank Clegg Profile
Frank Clegg
2015-04-23 16:31
I would also add, Ms. McLeod, that as a Canadian I am proud that we're leading the world on some things, like acid rain. I don't want to wait for an international consensus to act. I would be afraid to death that my future grandchildren would have to wait for the WHO to lead what I think is clear evidence today that Health Canada has the mandate, the authority, and the resources to lead the world, or be among the leaders, in fact, not even lead the world, but catch up to some countries. I would really resist relying on a WHO process.
When they did the IARC committee—and you'll hear from the next speaker, that the IARC committee, and Dr. Miller wrote the paper on the cancer section—you had a full body of scientists who had contrarian opinions. That's what I have learned over the last several years now is where good science happens. You have two sides of the debate and they get in a room and debate, as they did in 2011 when they debated among 30 scientists around the world. The WHO committee is not made up of a balance of scientists with opposing views.
Dariusz Leszczynski
View Dariusz Leszczynski Profile
Dariusz Leszczynski
2015-04-23 16:41
Thank you very much.
Thank you for inviting me to this hearing. It's an honour and a pleasure.
My name is Dariusz Leszczynski. I'm currently adjunct professor for biochemistry at the University of Helsinki, in Finland. I have done research in the area of biological and health effects of cellphone-emitted radiation since 1997. I was a member of the expert group of IARC, which in 2011 classified cellphone radiation as a possible human carcinogen.
When scientific evidence is unclear, contradictory, or ambivalent, careful and unbiased interpretation of it is of paramount importance. However, it is often the case that such scientific evidence gives room for a diverse interpretation that may lead to the development of contradictory expert opinions, causing confusion and impairing development of rational recommendations aimed at protecting the general population.
This is the current situation in the area of cellphone- and wireless communication-emitted radiation. Unclear experimental evidence leads to the polarization of the scientific opinions into two extremes: the no-effect opinion and the harmful-effect opinion. Currently scientists do not agree on the matter of biological and health effects of radiation exposures. The term “consensus” might be be misleading for the general public. We should rather speak about “differences in scientific opinion”.
A recent comment by the head of the World Health Organization's EMF project, Dr. Emilie van Deventer, well describes the current situation, and I will quote her comment given for The Daily Princetonian, “There is no consensus, it’s true. There’s a big group and a little group, but it’s still two groups.”
Talking about a big and a small group is a pure speculation because the size of the groups was never examined. From my nearly 19 years of experience in this area of research, I know that the vast majority of the scientists do not openly take a side in the debate.
The interpretation of scientific evidence by committee is of most use for the decision-makers. This is the reason that the development of unbiased opinions by committees are of paramount importance. Opinions of committees are defined by the expert composition. In an ideal committee, experts would not have conflict-of-interest issues and would be independent of any kind of lobbying; only science would matter. Nearly all of the committees dealing with the health effects of radiation emitted by wireless communication devices have a problem of biased expert selection, a potential conflict of interest, and a potential influence by an industrial lobby, which may occur in spite of set-up firewalls.
The majority of the committees consist of scientists having the same expert opinion. Individual committees experts commonly do not reflect all current scientific opinions. This concerns both international committees and national committees. This includes the committee in Canada that provided evidence for Safety Code 6. The composition of the Health Canada expert committee was clearly biased towards the no-effect opinion, and some of the experts are known to advise the telecom industry. This is a serious potential conflict of interest.
The above-mentioned system of firewalls to protect experts from influence of industry doesn't work. Industry sponsors know who receives funding; sponsored scientists know who provides funding. This is especially worrisome when the influential ICNIRP committee is in part funded by the industry through firewalls of the Royal Adelaide Hospital in Australia. The same goes for the EMF project of the WHO. If your experts know very well that the opinions of ICNIRP will be unfavourable for the telecom industry, their sponsorship may end. The firewall is only a gimmick.
Currently, WHO's EMF project is preparing an evaluation of the scientific evidence concerning health effects of radiation emitted by wireless communication devices, the so-called environmental health criteria for RF-EMF. The major problem with the draft document of environmental health criteria is the lack of balanced presentation of the scientific evidence. The environmental health criteria draft was written solely by scientists with a no-effect opinion.
The environmental health criteria document will have a global impact on billions of users of wireless technology and on the multi-trillion dollar business. This is why it is disturbing that preparation of such a document is solely reflecting opinions of ICNIRP, an organization with a firm, single-sided, no-effect opinion. This is a disturbing situation, where one group of scientists was given preferential treatment only because of their close link with the WHO and where other relevant expert opinions were deliberately and arbitrarily excluded without scientific debate.
Recommendations for decision-makers developed by committees, where memberships are consistently biased towards either a no-effect opinion or harmful effect opinion, are not representative of the whole currently available scientific evidence and should be viewed with extreme caution, or outright dismissed, until the proper, unbiased evaluation takes place.
To my knowledge there was only one scientific committee—IARC's working expert group in 2011, of which I was a member—where the full scope of diverse scientific opinions were represented. IARC classification completely disagreed with one-sided opinions of the majority of international and national committees, including Health Canada. Until an unbiased, round table of scientific debate takes place, where all scientific opinions will be duly represented and evaluated, the opinions developed to date by various international and national committees, based on biased expert selections, should be dismissed by decision-makers as insufficient.
According to year 2000 documents of the European Union on the precautionary principle, there are three criteria that need to be fulfilled in order to implement the precautionary principle. All of them are currently fulfilled.
Number one, scientific information is insufficient, inconclusive, or uncertain to make a firm decision. This is exactly what the IARC classification says on cellphone radiation as a possible human carcinogen, group 2B.
Number two, there are indications that the possible effects to human health may be potentially dangerous. Increased risk of brain cancer in long-term, avid users is a dangerous outcome, shown by three replicated epidemiological studies: European INTERPHONE, Swedish Hardell group, and French CERENAT studies.
Number three, the effects are inconsistent with the chosen level of protection. Epidemiological studies showing an increased risk in long-term, avid users were generated in populations using regular cellphones meeting all current safety standards. This means that the current safety standards are insufficient to protect users because the risk of developing cancer increases in long-term, avid users.
Proponents of the precautionary principle need to understand that precaution does not equal prevention of use of wireless technology. Requirements to develop more efficient, less radiation-emitting technology, and further biomedical research on the radiation effects, will create new knowledge through research and will create jobs in the research and technology. Implementation of the precautionary principle will not prevent technological developments. Claims by some that the implementation of the precautionary principle will cause economic stagnation are unfounded.
In the current situation of inadequate review of scientific evidence by groups of scientists with biased selection of members, and until the round table, unbiased review is performed, decision-makers should implement the precautionary principle. The reason is not that the harm was proven beyond doubt, but because the harm is possible and evidence is uncertain and suggesting that harmful health effects are possible. The precautionary principle was developed just for such situations where scientific uncertainty with concomitant indications of possible harm requires society to wait for more scientific evidence. Saying, “Better to be safe than sorry” applies here.
Thank you.
Andrew Adams
View Andrew Adams Profile
Andrew Adams
2015-03-24 15:32
Thank you very much. I have some opening remarks to make.
Chairman and members of the committee, it is my pleasure to be here today to speak on Health Canada Safety Code 6. My name is Andrew Adams, and I am the director of the environmental and radiation health sciences directorate in the healthy environments and consumer safety branch of Health Canada. I am joined today by Dr. James McNamee, the chief of the health effects and assessments division in the consumer and clinical radiation protection bureau and the lead author of Safety Code 6.
Safety Code 6 is Health Canada's guideline for exposure to radio frequency, or RF, electromagnetic energy, the kind of energy given off by cellphones and Wi-Fi, as well as broadcasting and cellphone towers. Safety Code 6 provides human exposure limits in the 3 kilohertz to 300 gigahertz frequency range, and we have provided chart A of the electromagnetic spectrum, just so committee members can situate the frequency range we're talking about.
But Safety Code 6 does not cover exposure to electromagnetic energy in the optical or ionizing radiation portions of the electromagnetic spectrum. Safety Code 6 establishes limits for safe human exposure to RF energy. These limits incorporate large safety margins to protect the health and safety of all Canadians, including those who work near RF sources.
While Safety Code 6 recommends limits for safe human exposure, Health Canada does not regulate the general public's exposure to electromagnetic RF energy.
Industry Canada is the regulator of radiocommunication and broadcasting installations and apparatus in Canada. To ensure that public exposures fall within acceptable guidelines, Industry Canada has developed regulatory standards that require compliance with the human exposure limits outlined in Safety Code 6.
I'd like to talk a little bit about the approach for updates to Safety Code 6. Safety Code 6 is reviewed on a regular basis to verify that the guideline provides protection against all known potentially harmful health effects and that it takes into account recent scientific data from studies carried out worldwide. The most recent update to Safety Code 6 was completed earlier this month. I will describe the process used for that update later in my remarks.
When developing the exposure limits in the revised Safety Code 6, departmental scientists considered all peer-reviewed scientific studies, including those pertaining to both thermal and non-thermal, and employed a weight-of-evidence approach when evaluating possible health risks from exposure to RF energy.
The weight-of-evidence approach takes into account both the quantity of studies on a particular end point and the quality of those studies. Poorly conducted studies receive relatively little weight, while properly conducted studies receive more weight.
Now I'll focus on the recent update of Safety Code 6.
The most recent update to Safety Code 6 was initiated in 2012, with the goal of ensuring that the most up-to-date and credible scientific studies on the potential effects of RF energy on human health were reflected in the code.
Health Canada proposed changes to Safety Code 6 that were based on the latest available scientific evidence, including improved modelling of the interaction of RF fields with the human body, and alignment with exposure limits specified by the International Commission on Non-Ionizing Radiation Protection. These changes were proposed to ensure that wide safety margins were maintained to protect the health and safety of all Canadians, including infants and children.
Some of you may recall that this committee previously conducted a study on the potential health impacts of RF electromagnetic radiation. Among the recommendations included in the committee's December 2010 report was a recommendation that:
Health Canada request that the Council of Canadian Academies or another appropriate independent institution conduct an assessment of the Canadian and international scientific literature regarding the potential health impacts of short and long-term exposure to radiofrequency electromagnetic radiation....
ln response to this recommendation, in 2013, Health Canada contracted the Royal Society of Canada to review the results of emerging research relating to the safety of RF energy on human health, to ensure it was appropriately reflected in the revised Safety Code, through a formalized expert panel process.
I'm sure you know that today we're joined by the chair of the expert panel and one of the members of the expert panel.
The Expert Panel of the Royal Society released their review in March 2014, concluding that in the view of the panel there are no established adverse health effects at exposure levels below the proposed limits.
Among the recommendations made by the expert panel was the suggestion that the proposed reference levels in the draft Safety Code 6 be made slightly more restrictive in some frequency ranges to ensure larger safety margins for all Canadians, including newborn infants and children.
ln the interest of openness and transparency, Health Canada also undertook a 60-day public consultation period for the proposed revisions to Safety Code 6 between May and July 2014. The department invited feedback from interested Canadians and stakeholders.
Comments related to the scientific and technical aspects of Safety Code 6 received by Health Canada during the public consultation period, as well as the recommendations provided by the Royal Society Expert Panel, were taken into consideration when finalizing the revised guideline.
The final version of Safety Code 6 was published on March 13, 2015. Health Canada also published a summary of the feedback received during the public consultation period. Given the scientific basis of the guideline, only feedback of a technical or scientific nature could be considered in the finalization of Safety Code 6; however, the summary of consultation feedback responds to both technical and non-technical comments received from Canadians.
With the recent update, Canadians should be confident that the radiofrequency exposure limits in Safety Code 6 are now among the most stringent science-based limits in the world.
To shift a little bit and talk about the scientific methodology that underlies the revision of Safety Code 6, a large number of submissions received during the public consultation period raised concerns that Health Canada had not considered all of the relevant scientific literature when updating Safety Code 6. ln particular, it has been stated that 140 studies were ignored. I would like to address that criticism here today.
ln updating Safety Code 6, Health Canada made use of existing internationally recognized reviews of the literature along with its own expert review of the relevant scientific literature. Numerous reviews on this issue have been written in recent years by international organizations such as the World Health Organization, the European Commission's Scientific Committee on Emerging Newly identified Health Risks, and ICNIRP. I believe we have provided links to some of these reports for the committee's interest.
While Safety Code 6 references these international reviews, the code is an exposure guideline, not a scientific review article. Accordingly, most individual scientific studies are not referenced in the code. However, this does not mean that Health Canada did not consider all relevant scientific information when deriving the science-based exposure limits in the code. I can assure you we did.
lt should be noted that studies with inappropriate study design or methodology can lead to erroneous results that are scientifically meaningless.
Studies were considered not to be of sufficient quality to inform the recent update if it was not possible to determine the dosage studied, if the study lacked an appropriate control, if experiments within the study were not repeated a sufficient number of times, if no statistical analysis of the results was conducted, or if other improper scientific techniques were used. Of the 140 studies that have been cited, a large number fall into this category.
Other studies were not considered to be within scope. For example, some of these studies looked at exposures to a frequency range outside of the frequency range covered by Safety Code 6 and were therefore not considered relevant.
However, Health Canada did consider all studies that were considered to be both in scope and of sufficient quality for inclusion in our risk assessment. While it is true that 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.
The conclusions reached by Health Canada are consistent with reviews of the scientific evidence by national and international health authorities. Of note, the European Commission's Scientific Committee on Emerging and Newly Identified Health Risks earlier this month released its final opinion on the potential health effects of electromagnetic fields. SCENIHR concluded that there are no evident adverse health effects, provided exposure levels remain below levels recommended by European Union legislation.
Now I'd like to talk a little bit about an international comparison. Members of the committee may be wondering how the limits in Safety Code 6 compare with limits in other parts of the world. I refer you to the chart of radio frequency exposure limits for the general public in different countries. Internationally, a few jurisdictions have applied more restrictive limits for RF field exposures from cell towers; however, there is no scientific evidence to support the need for such restrictive limits. Canada's limits are consistent with, if not more stringent than, the science-based limits used in such other jurisdictions as the European Union, the United States, Japan, Australia, and New Zealand.
In conclusion, the health of Canadians is protected form radio frequency electromagnetic energy when the human exposure limits recommended in Safety Code 6 are respected. Safety Code 6 has always established and maintained a human exposure limit that is far below the threshold for potentially adverse health effects. The health of Canadians was protected under the previous version of Safety Code 6, and recent revisions to the code ensure even greater protection.
Health Canada will continue to monitor the scientific literature on this issue on an ongoing basis. Should new evidence arise that indicates a risk to Canadians at levels below the limits in Safety Code 6, the department would take appropriate action.
Thank you for your time.
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