Scientists decry Canada’s outdated Wi-Fi safety rules

I wish to respond to the comments submitted by Dr. Loh and Dr. Padhi.

In their letter to the CMAJ they dismiss the Canadian Parliamentary Standing Committee on Health and our democratic process surrounding public health. They also advocate for ignoring an emerging public health issue, rather than officially recognizing it. It was an extraordinary letter to have been written by medical doctors, whose profession holds highest the health of its patients.

In their letter ridiculing the science that suggests caution from our cell phones and Wi-Fi, Loh and Padhi omitted the fact that over fifty Canadian MD's signed a submission calling for Health Canada to assist Canadian physicians in becoming apprised of microwave exposure and related health problems. (1)

Over 50 international scientists who specialize in research in the field of wireless radiation signed a declaration stating that Canada's guideline for wireless devices, (Safety Code 6) is fundamentally flawed. (2)

The MD's and scientists state that the current levels of Safety Code 6 do not protect Canadians. They also called for Health Canada to minimize exposure to wireless radiation, especially among children.

In testimony before the Parliamentary Health Committee, Mr. Andrew Adams of Health Canada admitted there are studies that show harm below Safety Code 6. (3)

In addition, Health Canada's "Analysis of 140 studies submitted by C4ST during Public Comment Period on Safety Code 6" lists 25 studies with "sufficient quality for inclusion in Risk Analysis" and are "in scope". Health Canada breaks them into the following categories: cancer is linked in 6 studies, brain/nervous system impacts in 13, biochemical disruption in 16 and 7 show development and/or learning behaviour impacts. (4)

The safety code Loh and Padhi defend was published in the 1970's and has not had any major revisions since. China, Russia, Italy and Switzerland have safety codes 100 times safer than Canada's. Loh and Padhi's comparing broadcast and emergency services radio signals to modern day cell phone and Wi-Fi exposure demonstrates a misunderstanding of the science. IARC and most international organizations treat exposure to this level of radiofrequency in a completely separate category.

Loh and Padhi state that "IARC's classification of Wi-Fi as a 2B "possible carcinogen" places it in the same category as coffee, talcum powder and aloe vera." In their narrow-minded presentation of their argument, they neglected to state that lead and DDT are in the same 2B category. We now limit these harmful substances and agents in the presence of children which is one of the purposes of the Class 2B List. To minimize the risk of wireless devices is a disservice to their patients. One of the experts who testified before the Parliamentary Health committee was Dr. Anthony Miller, Professor Emeritus, Dalla Lana School of Public Health, University of Toronto. Dr. Miller was a visiting senior scientist in the Monographs programme at IARC September 2011 - January 2012 which resulted in the 2B probable carcinogen designation. Dr. Miller has co-authored a paper which argues that the designation should, in fact, be increased to 2A, probable carcinogen. (5)

Dr. Dariusz Leszczynski, Adjunct Professor of Biochemistry, University of Helsinki, Finland also presented to Canada's Parliamentary Health Committee. He was part of the 30+ member scientific IARC panel that reviewed the scientific literature resulting in the 2B designation. Dr. Leszczynski expressed his concern to the Committee that there has not been a proper, thorough, independent review of the scientific evidence since that 2010 IARC review. (6) Dr. Leszczynski critiqued the process of "reviewing the reviews" of published evidence vs. reading all the scientific material. Given the references provided by Loh and Padhi, it is clear they are guilty of the same lazy habit criticized by experts in this field.

Loh and Padhi's personal attack on The CMAJ reporter Paul Webster demonstrates their lack of education on this issue. As you are aware, Mr. Webster is a world renowned reporter who has a reputation for conducting a thorough and complete review of the facts. It is my understanding that he conducted extraordinary research by today's standards of journalism and interviewed most, if not all of the eight independent experts who presented to the Committee. The four articles written by Mr. Webster over two years highlighting undisclosed conflicts and Health Canada's broken process should be commended, not ridiculed by uninformed individuals. Reporter Paul Webster should be congratulated for his coverage of this issue.

Your reporter Mr. Webster is accused by the authors of being "biased" and irresponsible" and of conducting a "crusade". In fact your reporter is one of the only ones accurately portraying the democratic process of Parliament in Canada on this issue.

Regarding myself, Loh and Padhi state, "In the article, Mr. Clegg insinuates that health regulators "failed to forestall public health disasters", naming "tobacco, asbestos, bisphenol A, thalidomide, DDT and urea formaldehyde. This assertion is laughable."

I would expect more from MD's such as Loh and Padhi who have taken an oath to "do no harm" in defending Health Canada's treatment of Canadians regarding thalidomide. Thalidomide was approved by the federal government in the early sixties as a "safe" sedative for pregnant women suffering from nausea and insomnia. More than 100 babies were born in Canada with extreme disabilities, including missing limbs, internal organ damage, deafness and blindness. As reported in the CMAJ, April 21st and July 14th, 2015, Ottawa announced a $180-million compensation package for 92 eligible thalidomide survivors and issued $125,000 lump-sum cheques for immediate health needs. For Loh and Padhi to state "regulators swiftly acted to safeguard the public's health once incontrovertible evidence of harm was found" after forty years, is the real laugh.

At the very least I would expect Drs. Loh and Padhi to curtail their profound and nearly anarchical disrespect for Canada's democratic process. To claim our government acted "swiftly" on Thalidomide betrays their basic misunderstanding of the timelines of cause, effect, and reconciliation in our country.

For example, Canada was among the last countries in the world to stop mining and exporting asbestos. Its last mine closed in 2011. (7) It has taken decades to recover from the asbestos material installed in hundreds of schools across Canada. The pitifully slow response of our health officials caused unnecessary harm to the health and finances of thousands of Canadians.

The first study published showing harm from tobacco was in 1939. (8) The Standing Committee on Health, Welfare and Social Affairs was the first thorough public airing of the tobacco and health issue in Parliament since 1908. The Committee presented its final report to Parliament on December 18, 1969. The seventeen recommendations included a ban on advertising and promotion, increasing educational efforts to discourage cigarette smoking, health warnings on all cigarette packages and cartons, more help for victims of smoking, more help for smoking cessation, and gradually increasing no-smoking zones in public places. Only a few of the recommendations were effectively implemented in the 1970s. Significantly, none of the legislative recommendations were implemented for almost 20 years. (9)

The Parliamentary Committee on Health presented its report to Parliament regarding Safety Code 6 on June 9th, 2015. Some of its twelve recommendations are very similar to the tobacco recommendations in 1969. Marketing of radiation emitting devices to children under the age of 14, an awareness campaign relating to the safe use of wireless technologies, key medical associations in Canada consider updating their guidelines and continuing education materials regarding the diagnosis and treatment of electromagnetic hypersensitivity and finally, examine measures taken and guidelines provided in other countries to limit the exposure of vulnerable populations, including infants, and young children in the school environment.

The first evidence of harm from wireless devices was published over a decade ago. Hopefully Health Canada and other health officials will have learned from the tobacco, asbestos and thalidomide debacles. Reporting by Mr. Webster and coverage in credible publications such as the CMAJ will keep the focus on this issue so we aren't sitting here in 2025 wishing we had acted sooner.

References

(1). http://www.c4st.org/images/documents/hc-resolutions/medical- doctors-submission-to-health-canada-english.pdf

(2). http://www.c4st.org/images/documents/hc-resolutions/scientific- declaration-to-health-canada-english.pdf

(3). http://www.parl.gc.ca/HousePublications/Publication.aspx?DocId=7936469&Language=E&Mode=1&Parl=41&Ses=2 at time 1540

(4). http://www.c4st.org/HESA2015

(5). http://www.ncbi.nlm.nih.gov/pubmed/23664410

(6). http://www.parl.gc.ca/HousePublications/Publication.aspx?DocId=7936469&Language=E&Mode=1&Parl=41&Ses=2 at time 1640

(7) http://www.theglobeandmail.com/news/national/ottawa-reverses-stance-on -health-risks-of-asbestos-in-landmark-shift/article25224035/

(8). M?ller FH. Tabakmissbrauch und Lungencarzinom. Zeitschrift fuer Krebsforschung 1939; 49: 57-85.

(9). http://www.smoke- free.ca/pdf_1/2009/history%20of%20tobacco%20control%20in%20canada.pdf

Conflict of Interest:

None declared

Sir/Madam:

Your recent article "Scientists decry Canada's outdated Wi-Fi safety rules" (1) represents irresponsible journalism designed to stoke fear, sullying CMAJ's reputation as Canada's medical journal of record. The print edition in which the article appears is even more ironic; your back page Digestif quotes a blog (written by one of this letter's co-authors) calling for "media, medicine and public health [...] to support each other in spreading truth in science and health", (2) and the article itself insets an accusatory quote that current Wi-Fi guidelines are a "disaster for public health." (1)

On the contrary, articles like this are themselves a disaster for Public Health, conferring undeserved attention to unfounded fears and requiring a response; one recalls the Toronto Star's Gardasil debacle. Addressing media irresponsibility detracts from the real work being done by public health on health issues with much stronger evidence.

Your biased piece quotes five scientists (purportedly independent, but not so) (3) and an advocate (whose motivations have been heavily questioned, even in popular media) (4) against a sole regulator who is blatantly depicted as defending a supposedly "corrupt" regulatory process. Notably, the article's author has been on a seeming crusade against Wi-Fi, publishing similar pieces in CMAJ since 2013. (5-8) The article's enormous lack of balance is striking in that no mainstream physician or epidemiologic experts on Wi-Fi were interviewed.

A responsible approach would have involved a closer examination of the science and perhaps engagement with the National Collaborating Centre for Environmental Health, any number of provincial public health agencies, academics with a contrarian view, and/or relevant international bodies. On the last point, one can't also help but question why the author quoted the opinion of a past secretary of the International Agency for Research on Cancer (IARC), instead of asking for comment from current IARC leadership regarding Wi-Fi's present carcinogenicity classification.

Many of the studies cited in the article have been reviewed by experts in Canada and elsewhere, including the United States (9) and United Kingdom. (10) The worldwide consensus consistently deems these studies to be scientifically unsound. For studies finding associations, which mostly exclusively arise from Hardell et al., replicability has been difficult, and is often contradicted by many other well conducted cohort studies that to date have consistently failed to find an association. (11- 13) Additionally, bench laboratory findings by Lai et al. that occur at the microscopic level are often disputed, and more importantly, have not translated into actual health outcomes at a macro level.

In the article, Mr. Clegg insinuates that health regulators "failed to forestall public health disasters", naming "tobacco, asbestos, bisphenol A, thalidomide, DDT and urea formaldehyde." This assertion is laughable. If anything, determining the potential carcinogenicity of an exposure involves a rigorous, scientific process that engages the entire body of evidence and all sides of an issue within the community. On these past issues named by Clegg, regulators swiftly acted to safeguard the public's health once incontrovertible evidence of harm was found. In the same vein, IARC's classification of Wi-Fi as a 2B "possible carcinogen" places it in the same category as coffee, talcum powder and aloe vera. This categorization appropriately reflects the current lack of evidence of cancer risk from these exposures.

Most crucially for Wi-Fi, any evidence would need to be extremely compelling to overcome the biologically implausible argument that Wi-Fi (and other radiofrequency based technologies), as a non-ionizing radiation, would be able to cause DNA damage or other biological changes. The only broadly recognized biological effect observed with non-ionizing radiation exposure has been thermal effects. Specific to RF, these typically occur at exposure levels well in excess of Safety Code 6 limits. It is also worth noting that our population has been exposed without controversy to radiofrequency long before the proliferation of cellular telephones and Wi-Fi. This includes historic and ongoing exposure to broadcast, emergency services radio, and radar emissions throughout Canada.

IARC and expert panels and academics all over the world have long stated that present literature is unclear and at present shows no consistent evidence of cancer risk associated with radiofrequency exposure, including Wi-Fi. Continuing research hopes to better inform this controversy. That your article ignored this still-open state of affairs, wilfully or otherwise, significantly diminishes its legitimacy. A more responsible journal might have rejected this article and perhaps engaged the broader scientific and medical community in reviewing all the available evidence. By proceeding with this piece, one wonders if the allure of publishing a catchy story, despite its obvious flaws, was adequately weighed against the resultant harm to CMAJ's credibility.

References

1. Webster PC. Scientists decry Canada's outdated Wi-Fi safety rules. CMAJ. 2015 Jun 16;187(9):639-40. doi: 10.1503/cmaj.109-5061. Epub 2015 May 11.

2. Canadian Medical Association. Digestif. CMAJ. 2015 Jun 16; 187(9):704

3. Cellular Phone Task Force. Declaration: Scientists call for Protection from Radiofrequency Radiation Exposure. 2014 July 9 [accessed 2015 June 18] Available from: http://www.cellphonetaskforce.org/wp- content/uploads/2014/07/scientific-declaration-to-health-canada- english.pdf

4. Urback, R. Former Microsoft Canada head joins bizarre fight to protect schoolchildren from Wi-Fi. National Post [internet]. 2013 May 16. [accessed 2015 Jun 18.] Available from: http://news.nationalpost.com/full- comment/robyn-urback-former-microsoft-canada-head-joins-bizarre-fight-to- protect-schoolchildren-from-wi-fi

5. Webster PC. Federal Wi-Fi safety report is deeply flawed, say experts. CMAJ. 2014 Jun 10;186(9):E300. doi: 10.1503/cmaj.109-4785. Epub 2014 Apr 22.

6. Webster PC. Second Wi-Fi panel member's conflicts are problematic. CMAJ. 2013 Sep 17;185(13):E605. doi: 10.1503/cmaj.109-4565. Epub 2013 Aug 12.

7. Webster P. Chair of Wi-Fi safety panel steps down. CMAJ. 2013 Sep 3;185(12):E573. doi: 10.1503/cmaj.109-4549. Epub 2013 Jul 22.

8. Webster PC. Federal Wi-Fi panel criticized for undisclosed conflict. CMAJ. 2013 Aug 6;185(11):E515-6. doi: 10.1503/cmaj.109-4523. Epub 2013 Jun 24.

9. Federal Communications Commission. Wireless devices and health concerns. [internet, accessed 2015 June 18.] Available from: https://www.fcc.gov/guides/wireless-devices-and-health-concerns

10. UK Health Protection Agency. Health Effects from Radiofrequency Electromagnetic Fields: Report of the Independent Advisory Group on Non- ionising Radiation. 2012 [accessed 2015 June 18.] Available from: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/333080/RCE -20_Health_Effects_RF_Electromagnetic_fields.pdf

11. INTERPHONE Study Group. Acoustic neuroma risk in relation to mobile telephone use: results of the INTERPHONE international case-control study. Cancer Epidemiol. 2011 Oct;35(5):453-64. doi: 10.1016/j.canep.2011.05.012. Epub 2011 Aug 23.

12. Little MP, Rajaraman P, Curtis RE, Devesa SS, Inskip PD, Check DP, Linet MS. Mobile phone use and glioma risk: comparison of epidemiological study results with incidence trends in the United States. BMJ. 2012 Mar 8;344:e1147. doi: 10.1136/bmj.e1147.

13. Repacholi MH, Lerchl A, Roosli M, Sienkiewicz Z, Auvinen A, Breckenkamp J, d'Inzeo G, Elliott P, Frei P, Heinrich S, Lagroye I, Lahkola A, McCormick DL, Thomas S, Vecchia P. Systematic review of wireless phone use and brain cancer and other head tumors. Bioelectromagnetics. 2012 Apr;33(3):187-206. doi: 10.1002/bem.20716. Epub 2011 Oct 21.

Conflict of Interest:

None declared