The Inadequacy of Existing Safety Guidelines 
 
Existing Safety Guidelines, based solely on consideration of the SAR, afford no protection against the 
frequency -specific90 effects that have been the subject of this Study, since they limit only the 
intensity  of the microwave radiation sufficiently to ensure that tissue heating by absorption of energy 
from the microwaves is not in excess of what can be coped with by the body’s thermoregulatory mechanism, so that temperature homeostasis is not compromised. Furthermore, it must be appreciated that the aliveness of the organism here enters only in so far as it dictates the magnitude of the temperature rise above which adverse health effects set in, the heating itself  occurring 
irrespective  of whether the organism is alive or dead. In justifying the exclusion of any non-thermal  input into the formulation of their Safety Guidelines, 
ICNIRP  conclude
2: 
 …...‘ Overall, the literature on athermal effects of amplitude modulated electromagnetic fields is so 
complex, the validity of the reported effects so poorly established, and the relevance of the effects to human health is so uncertain, that it is impossible to use this body of information as a basis for setting limits on human exposure to these fields. ’   
 
It is to be stressed that this is not equivalent to denying the existence of non-thermal influences of 
this kind of radiation, or their potential to provoke adverse health reactions  - as is often 
maintained by the Mobile Phone Industry – but simply that in ICNIRP ’s view (because for the 
reasons stated) such effects cannot be used as a basis for setting exposure limits. Let us consider each point in turn. As an example of the complexity of athermal ( i.e. non-thermal) effects, the 
following statement appears in the paragraph preceding the one from which the above quotation is taken:  …..‘Interpretation of several observed biological effects (of this kind of radiation) is complicated by 
the apparent existence of ‘windows’ of response in both power and frequency domains. There are no accepted models that adequately explain this phenomenon, which challenges the traditional concept of a monotonic relationship between the field intensity and the severity of the resulting biological effects.’    An absence of such a monotonic (‘dose-response’) relationship is, however, actually to be expected , 
since one is dealing with living  organisms whose very aliveness means that they are far from thermal 
equilibrium, and hence well beyond the regime where such a m onotonic relationship can be expected 
to hold. Being held far from thermal equilibrium, their res ponse to an external electromagnetic field, 
for example, necessarily depends on the state of the organism at the time when it is exposed - i.e. one 
is dealing with what are known as non-linear  systems, for which exposure to a weak microwave 
field does not necessarily entail a correspondingly weak response, or vice versa,  and for which the 
‘window’ phenomena referred to are actually to be expected
9, 10! (In this connection, it should be 
remembered that the concept of a dose-response relationship is one inherited from toxicology, and as such, is in general, inappropriate  in the present context. For electromagnetic fields are not alien  to 
the alive organism, but play a fundamental and integral role in its organisation and control, as already noted.) 22  
 This dependence of non-thermal influences on the state of the alive organism must, in general, be 
expected to undermine the reproducibility of their detection, thus accounting for the reported effects being (in some cases) ‘ poorly established ’. Accordingly, such difficulties should, more positively, 
be considered as a biological fact of life – indeed as a ‘hallmark’ of aliveness! It should be noted that the ‘poorly established’ claim is not universally accepted, as evidenced both by the Vienna Resolution
3 of 1998, signed by 16 researchers of international standing, and by a recent analysis91 of 
the ICNIRP  document, which claims that it contains….‘ a consistent pattern of bias, major mistakes 
and deliberate misrepresentations’. The least contentious part of the quotation is, of course, the question of the relevance of non-thermal effects (assuming their existence is accepted) to human health - it being, of course, essential to appreciate that the occurrence  per se  of non-thermal effects does not  mean that they necessarily  
entail adverse health consequences, as already stressed. In order that the radiation can exert  non-thermal influences, it is essential that the organism be alive , 
for only then are the various oscillatory endogenous electrical activities excited, via which the 
radiation can access the system: the Dead have no ECG  or EEG  with which an external 
electromagnetic field can interfere! Thus, just as a radio or another piece of electronic instrumentation has to be switched on (or energised) before it can respond to or be interfered with by an extraneous incoming signal, so the organism has itself to be energised ( i.e. be alive) if it is to be 
non-thermally sensitive to radiation. Existing Safety Guidelines thus neglect the most discriminating 
feature of all, namely, the aliveness  of the irradiated organism ; they address only ‘one side of the 
coin’ - the thermal side - leaving the exposed person vulnerable to the possibility of adverse health effects provoked by the neglected non-thermal  side. The same indictment, of course, applies to any 
protection device that acts simply to reduce - either by screening or by an employing an ear-piece, for example - the intensity of the microwave radiation emitted by a mobile phone into the head of the user; for the user is still left vulnerable to any adverse health effects that might be provoked by the neglected frequency dimension. Clearly, non-thermal influences are connected more with the transfer of information  from the 
irradiating field to the alive organism, through the latter’s ability to ‘recognise’ certain frequency  
characteristics of the radiation
92, than with its ability to absorb energy from the field. In order, 
however, for the organism to be able to discern such weak radiation against the level of its own thermal emission  at physiological temperatures, the radiation must have a certain minimum intensity. In the case of microwave radiation, this minimum intensity is, however, far below  (of the order of 
10
-15 Watts/cm2) even that at which non-thermal effects manifest themselves, in consequence of the 
radiation’s rather well-defined carrier frequency (or relatively high degree of coherence). It should be noted that the magnitude of this minimum power density is close to those that characterise the human thresholds of  EEG  response
93, and also of sight and hearing. Given that the typical power 
densities in the main beam near ground level some hundreds of metres from a typical base-station, and also in the often neglected ‘side-lobes’, are many orders of magnitude higher  than these 
threshold values, it is clear that the ability of the alive human organism to discern base-station radiation is  not at all contingent on a sensitivity that is in any way superior to those that it already 
possesses (quite undisputedly) in the case of other exogenous fields of physiological relevance. 23  
  
B-9. Some recommendations to enhance electromagnetic bio-compatibility 
 
9.1. Policy options for the European Parliament 
• That the non-emergency use of mobile phones by children – and particularly per-adolescents – be 
strongly discouraged, on account of their increased vulnerability to any potential adverse health effects. • That the Mobile Phone Industry be required to refrain from promoting the use of mobile phones 
amongst children by the use of advertising tactics exploiting peer pressure and other strategies to which the young are particularly susceptible, such as the (now discontinued) use of DISNEY characters fascias on the phones. • That the Mobile Phone Industry be required to make it clear to the consumer that the value of the 
specific absorption rate ( SAR) - which in some countries is shortly to be declared on the handset - 
refers only to the degree to which the microwave emissions from the antenna can heat biological 
tissue, and is in no way  relevant to non-thermal  effects that the emissions from a mobile phone 
may have on the user. • Concerning commercially available personal protection devices claiming to protect the user of a 
mobile phone against the microwave emissions from the antenna, it be required that: 
 
a) The efficacy of devices such as shields and ear-pieces be proven on the basis of biological 
tests, and not marketed solely on the reduction in SAR value (as determined by the use of a 
‘phantom’ head) that their use might achieve. b) It be made clear to the consumer that such devices afford no protection against the low 
frequency pulsed magnetic field from the battery of the phone. • Concerning commercially available personal protection devices claiming work by boosting the 
immunity of the user against any adverse impacts of exposure (including those from the battery magnetic field), it be required that:  
 
a) The efficacy of such devices be established by biological testing. b) Such devices not be rejected (as has occurred in certain consumer surveys that have been 
published) solely on the grounds that their use does not achieve any reduction in SAR, as 
measured using a ‘phantom’ head; for this is not what they are designed to do. Accordingly, the SAR is here a fundamentally inappropriate  metric against which to assess their efficacy. [It should, however, be appreciated that in the case of real human exposure  – as opposed to that involving 
a ‘phantom’ head – such devices could conceivably achieve a reduction in SAR if they somehow increase 
the efficiency of the body’s thermoregulatory mechanism; in this way, anecdotal reports of a diminution in heating sensation when a phone is equipped with one particular such device might be rationalised.] 9.2 Policy options for the European Commission 
• Future  research sponsored by the EC, should incorporate the following recommendations: 
 
a) That the living systems under investigation be exposed to the emissions of an actual mobile 
 
24  
 phone, as opposed to those of a ‘surrogate’, since the emissions from the former can be expected 
to have a quite different biological impact, in consequence of certain pulse frequency differences. b) That in assessing the significance to humans of results obtained using animals, particular 
attention be given to differences in exposure conditions, such as whether exposure is size-resonant or non-resonant, whether it is to the near or far field of the antenna, and whether whole-body or of more localised exposure occurs. c) That systematic investigation be made of the influence of different kinds of pulsing (of real 
phones) on the human EEG , and ideally on the MEG , and of whether any observed changes in 
power spectra are correlated with changes in the level of deterministic chaos. d) That use be made of novel, non-invasive technologies, such as biophoton emission, to 
investigate the influence of mobile phone radiation on living systems. e) That in assessing the noxiousness of mobile phone radiation more attention be paid to lessons 
that have been learnt from exposure to other kinds of related radio frequency fields, such as those from the Skrunda, military and police radars. f) That, in the light of reports of cattle being quite seriously adversely affected at farms where 
there is a base-station, a veterinary monitoring service be established to collect and analyse such reports, and raise awareness amongst farmers of this potential hazard to their livestock. • Attempts should be made – perhaps under the aegis of national regulatory bodies - to increase 
awareness of the fundamentally electromagnetic nature of the alive organism, and of its associated hypersensitivity to coherent, ultraweak electromagnetic signals of technological origin. [Until this is achieved, the necessity of extending existing thermally based safety guidelines, by 
incorporating therein the dimension of electromagnetic biocompatibility, is unlikely to be accepted, and the public will remain vulnerable to any adverse health effects provoked by non-thermal electromagnetic influences on the alive human organism.] 9.3 Technological options at the operational level 
Whilst the question of precisely how adverse health effects can be provoked by non-thermal 
influences of the pulsed microwave radiation currently employed in GSM  telecommunication, as well 
as those from ELF fields associated with other technologies, is far from resolved, the circumstantial 
evidence consistent with such influences suggests at least two ways in which biocompatibility with this technology could be enhanced by interventions involving the fields alone: 
 
• In the case of exposure to GSM radiation, reduce intensities to the level below which no adverse 
effects have been empirically found in exposed populations, bearing in mind that there are indications of non-thermal thresholds for biological effects of the order of microwatt/cm
2. Power 
densities a few tenths  of this value are common at distances of 150-200m from a typical 15m 
high Base-station mast and within the range of the more localised side-lobes in the immediate vicinity of a mast - adverse effects being reported at both locations . Incorporating a further 
safety factor of 10 indicates that, at locations where there is any long-term exposure, power 
densities should not exceed 10 nano W/cm
2. [To appeal to the (alleged) absence of health problems associated with the higher power density 
electromagnetic fields associated with radio/TV transmissions in an attempt to justify the retention of the present level of emission from GSM  Base-stations is untenable on at least two accounts: ( i) the nature of 
 
25  
 the emissions are quite different, with respect to carrier frequencies, modes of transmission 
(pulsed/analogue), and beam morphology, ( ii) there are94-96 health problems connected with some  such 
transmitters, contrary to what is often claimed!] • Ensure that there is no ELF frequencies – either of amplitude modulations (including pulsing, as 
the extreme case) of RF fields, or of other electric /magnetic fields - in the range of human 
electrical brain-wave activity, or windows of calcium efflux. [In the case of exposure to GSM radiation, this will be achieved, to a certain extent, with the advent of the 
Third Generation of mobile phones ( UMTS ) that utilise CDMA in place of TDMA. For although any 
sensitivity to the microwave carrier will remain, the pulsing used in CDMA  is irregular ; accordingly, 
CDMA  radiation cannot enjoy the same ‘oscillatory similitude’ with the human brain-wave activity and 
electrochemical processes as does TDMA . In consequence, however, of the somewhat higher carrier 
frequency used, which is closer to where water strongly absorbs microwaves, thermal  effects could here 
become more of a problem, particularly in view of the somewhat higher powers at which they operate! The introduction of TETRA , similarly gives rise to an increased  level of (non-thermal) concern, for the 
reasons already stated in Section B-1 .] B-10. Conclusions 
 
Absorption of microwave radiation causes heating of biological tissue, which if excessive is deleterious to health; this is undisputed, and forms the basis of current Safety Guidelines, both national and international. In the case of exposure to the microwave radiation used in GSM , these 
Guidelines are generally not violated. Indeed, in the case of the emissions from base-stations, it has been repeatedly confirmed by field measurements that the emissions are far below - by many orders 
of magnitude - the limits set by the Guidelines. What is currently disputed, however, is whether, in 
the case of the alive human organism, this radiation can exert other, more subtle, kinds of non-thermal influences, which might also entail adverse health consequences. The root of the continuing public concern is that if this is, in fact, the case, then the existing guidelines afford an inadequate level of protection, in that they leave an exposed person vulnerable to these non-thermal hazards. As has been explained, the heating ability of microwave radiation depends primarily on its intensity, and it is essentially only this that the Guidelines restrict. Non-thermal  effects, on the other hand, 
depend primarily on the existence of an ‘oscillatory similitude’ between the frequencies of the radiation and those of certain endogenous biological electrical activities that the organism supports when alive, which effectively opens it to informational aspects of the radiation; it is this dimension of the problem that is not addressed by existing Safety Guidelines. Whilst the existence of non-thermal influences is readily accepted in the case of active electronic instrumentation exposed to GSM  radiation, the same does not currently prevail in the case of the 
alive human organism, which is generally considered immune to any effect other than heating, despite the fact that, in the case of mobile phone use, the brain (the most sensitive organ of the body) 
is, for the first time in its evolutionary history, being exposed at short range to a source of both pulsed microwaves (from near-field of the antenna) and more highly penetrating ELF magnetic fields 
(from the battery). This conviction continues to persist - particularly in Regulatory Circles - despite the fact that the possibility of non-thermal influences on living systems of the kind of radiation used in mobile telephony is a rather general prediction of modern, non-linear biophysics, and one that is 
 
26  
 supported by 30 years of evidence, both of non-thermal effects per se , and of associated adverse 
health reactions, in particular – not only from exposure to GSM radiation, but also to that from other kinds of installations that emit microwave and RF radiation of an intensity at locations of human and 
animal exposure that is comparable to that realised several hundreds of metres from a base-station. Two principal reasons for this state of affairs have been identified: 1) the negative outcome of some attempts to independently replicate certain non-thermal effects, even in vitro , the acceptance of 
which is not helped by their often counterintuitive nature (but only from a linear perspective), and 2) uncertainty as to whether such effects (assuming they are real) necessarily entail adverse health 
reactions. Both these problems have been addressed, and attention drawn ( i) to the fact that 
difficulties in corroboration are actually to be expected as a hall-mark of the ‘alive’, and thus s hould, 
more positively, be accepted as a ‘biological fact of life’, and ( ii) to the existence of a certain 
empirical consistency between the contentious non-thermal effects and the types of adverse health effects (mainly neurological) reported by some people when exposed to GSM  radiation, as well as 
that (the indication of an increased incidence of brain cancer amongst mobile phone users) found epidemiological – a consistency that further enhances the credibility of the non–thermal effects, and one that will hopefully motivate further research (from the necessary non-linear standpoint, of course) towards establishing their causal connections with presenting pathologies. In conclusion, and in accord with philosophy espoused by the World Health Organisation, it can hardly be disputed that to enjoy an acceptable quality of life requires more than simply an absence of terminal disease. In this respect, even adverse health effects of a non-life threatening kind  that might 
be provoked by exposure to GSM  radiation  must be considered unacceptable, in that they 
undoubtedly have a debilitating effect that undoubtedly undermines the general well-being of those affected, and which in the case of certain pre-adolescent children could well undermine their scholastic and neurological development. ………………………………….. 
 
 
27  
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radiation, distinguished by their frequency and degree of coherence, and by the much greater penetrability of microwave radiation into tissue and bone. 84. Personal communication to the Author, 1998. 85. Although the energy of a GSM  microwave quantum is insufficient to break molecular bonds 
(i.e. the radiation is non-ionising), it is possible that it ( i) initiates subtle conformational 
changes, resulting in certain undesirable biochemical consequences, ( ii) interferes with the 
natural process of DNA repair, resulting in a higher degree of fragmentation than would 
 
33  
 otherwise obtain. 86. ‘Mobile Phones and Health’, Report of the Independent Expert Group on Mobile Phones, 
May, 2000. 87. Gandhi O.P. et al. Electromagnetic absorption in the human head and neck for mobile 
telephones at 835 and 1900MHz. IEEE Trans. MTT 1996; 44: 1884-1897. 88. A similar non-uniqueness, it should be noted, also characterises the biological consequences of 
microwave heating, where, for example, a temperature rise of 1oC can be either lethal or life-saving 
depending on the condition of the person at the time. Thus whilst there is a uniquely predictable physical consequence of exposure to microwave radiation of a sufficient intensity – namely an 
increase in body temperature - the biological  consequence of a given temperature rise cannot  be 
uniquely predicted, since this depends on the physiological condition of the exposed, which varies  
from person to person. To cover a reasonable range of conditions, a certain safety margin is incorporated into the permitted microwave exposure intensity; indeed, it is a lack of consensus as to what the magnitude  of this margin should actually be that is partly responsible for the variation in the 
exposure intensities recommended by different regulatory bodies. It is to be stressed, however, that the heating itself always  occurs, irrespective  of the physiological 
condition of the person (even whether alive or dead! ), quite unlike the situation with non-thermal effects. It is, of course, this fact that underlies the possibility of using ‘phantom’ heads to determine  
SAR values; it should, however, be realised that the reliability of the values so obtained is contingent 
on the extent to which the dielectric properties of the synthetic brain fluids used actually approximate 
to those in the alive  human brain. On the basis of what little information is available, the differences 
could prove to be significant. 89. New Scientist, Editorial , 4th November, 2000. 90. The carrier frequency is taken into account only in so far as it affects the absorbability of the 
radiation through size resonance. 91. Cherry, N. ‘Criticism of the Proposal to a dopt ICNIRP Guidelines for New Zealand’, Lincoln 
University, N.Z., 1998. 92. A good example of such ‘information’ transfer is the ability of a light flashing at a certain rate 
(between 15 to 20Hz) to induce seizures in photosensitive epileptics. It is not so much a question of the amount of energy deposited by the light (which depends on its intensity) that provokes the seizure, but rather the fact that the flash frequency is ‘recognised’ by the brain because it is close to one characterising a particular brain activity - in this case, that associated with seizures. 93. Bise W. Low power radio-requency and microwave effects on human electro- 
encephalogram and behaviour. Physiol. Chem. & Physics 1978; 10: 387-398. 94. Hocking, B. et al. Cancer incidence and mortality and proximity to TV towers. Medical J. 
Australia 1996; 165: 601-605. 95. Dolk, H. et al. Cancer incidence near radio and television transmitters in Great Britain. American J. of Epidemiology 1997; 145(1): 1-9, 10-17. 34  
 96. Goldsmith, J.R.  Epidemiological evidence of radiofrequency radiation (microwave) effects 
on health in military, broadcasting, and occupational studies. Int. J. Occup. Environ. Health 
1995; 1: 47-57. ………………………………….. 
 
 
  
  
                                    
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The_effects_of_EMF.txt
Summarize the following text section accurately and concisely. Maintain specific details and numerical information, and use anti-repetition mechanisms:

        The Inadequacy of Existing Safety Guidelines 
 
Existing Safety Guidelines, based solely on consideration of the SAR, afford no protection against the 
frequency -specific90 effects that have been the subject of this Study, since they limit only the 
intensity  of the microwave radiation sufficiently to ensure that tissue heating by absorption of energy 
from the microwaves is not in excess of what can be coped with by the body’s thermoregulatory mechanism, so that temperature homeostasis is not compromised. Furthermore, it must be appreciated that the aliveness of the organism here enters only in so far as it dictates the magnitude of the temperature rise above which adverse health effects set in, the heating itself  occurring 
irrespective  of whether the organism is alive or dead. In justifying the exclusion of any non-thermal  input into the formulation of their Safety Guidelines, 
ICNIRP  conclude
2: 
 …. ‘ Overall, the literature on athermal effects of amplitude modulated electromagnetic fields is so 
complex, the validity of the reported effects so poorly established, and the relevance of the effects to human health is so uncertain, that it is impossible to use this body of information as a basis for setting limits on human exposure to these fields. ’   
 
It is to be stressed that this is not equivalent to denying the existence of non-thermal influences of 
this kind of radiation, or their potential to provoke adverse health reactions  - as is often 
maintained by the Mobile Phone Industry – but simply that in ICNIRP ’s view (because for the 
reasons stated) such effects cannot be used as a basis for setting exposure limits. Let us consider each point in turn. As an example of the complexity of athermal ( i. e. non-thermal) effects, the 
following statement appears in the paragraph preceding the one from which the above quotation is taken:  …. ‘Interpretation of several observed biological effects (of this kind of radiation) is complicated by 
the apparent existence of ‘windows’ of response in both power and frequency domains. There are no accepted models that adequately explain this phenomenon, which challenges the traditional concept of a monotonic relationship between the field intensity and the severity of the resulting biological effects. ’    An absence of such a monotonic (‘dose-response’) relationship is, however, actually to be expected, 
since one is dealing with living  organisms whose very aliveness means that they are far from thermal 
equilibrium, and hence well beyond the regime where such a m onotonic relationship can be expected 
to hold. Being held far from thermal equilibrium, their res ponse to an external electromagnetic field, 
for example, necessarily depends on the state of the organism at the time when it is exposed - i.
They do not consider the possibility of non-thermal effects and the aliveness of the organism.
What is the main limitation of the existing safety guidelines?
The potential for adverse health effects, particularly in children and vulnerable populations.
What is the main concern about the use of mobile phones?
It highlights the complexity of biological responses to electromagnetic radiation and the need for a more nuanced understanding of the effects on living organisms.
What is the significance of the "window" phenomenon in the context of non-thermal effects?
It only addresses thermal effects and does not account for non-thermal influences, which may be more relevant in the case of mobile phone use.
What is the main issue with using SAR as a metric for assessing the safety of mobile phone radiation?
Reduce the power density of the radiation to below the threshold values, and consider the use of novel, non-invasive technologies to mitigate the effects.
What is the recommendation for reducing the risk of adverse health effects from mobile phone radiation?