The authority of organizations such as the International Commission on Non-Ionizing Radiation Protection (ICNIRP) in determining exposure guidelines for radiofrequencies has been called into question by many researchers. This is due to a number of factors, including the use of fallacious reasoning, a lack of consideration for non-thermal effects, and the use of averaging as a measure of harm. Additionally, the potential for bias and conflicts of interest within these organizations has also been raised.
Critics have argued that the ICNIRP’s guidelines are based on a narrow focus on thermal effects, disregarding the potential for non-thermal effects and biophysical harm. Furthermore, the use of averaging as a measure of harm can lead to inaccurate conclusions about the safety of exposure to radiofrequencies, potentially putting individuals at risk.
It is important for organizations such as the ICNIRP to consider all available evidence, including non-thermal effects, and to recognize the limitations of averaging and the potential for biophysical harm. Additionally, measures should be taken to ensure the transparency and independence of these organizations, to avoid any potential conflicts of interest or bias.
The advent of fifth-generation (5G) wireless communication technology utilizing near-millimeter radiofrequency waves (mmWaves) has raised concerns about the long-term effects on human health and the environment. Despite the lack of conclusive evidence on the safety of 5G technologies, industry and government advisory bodies have used the scientific uncertainty to reassure the public. This article aims to provide a visible overview of the existing mmWave evidence base by examining the science and communication of the research, and identifying errors in reasoning that cloud judgements and conclusions.
A literature search was performed using the Oceania Radiofrequency Scientific Advisory Association (ORSAA) Database of EMF Bioeffects (ODEB) to gather all relevant peer-reviewed studies investigating the biological and health effects of electromagnetic fields on humans, animals, and the environment. The search included papers that used radiofrequencies above 6 GHz and exposure intensities below the International Commission on Non-Ionizing Radiation Protection (ICNIRP) limits. The result was a set of 295 papers, comprising 238 experimental papers and 57 epidemiology papers. This is a relatively small knowledge base, given the many combinations of experimental parameters requiring examination.
The main themes investigated in the mmWave literature include the effects on the cardiovascular system, the nervous system, and the reproductive system. A significant number of studies show effects, while a smaller number show no effects. However, it is important to note that the current literature is not comprehensive and does not provide clear evidence for or against the safety of mmWaves. Further research and a more formal systematic review approach are needed to better understand the potential harm of mmWaves.
HOW IT WAS CONDUCTED
The study was conducted by the Oceania Radiofrequency Scientific Advisory Association (ORSAA) by creating a database called the ORSAA Database of EMF Bioeffects (ODEB). The ODEB was first established using the entire research database of the Australian Radiation Protection & Nuclear Safety Agency (ARPANSA) and then expanded to incorporate all relevant papers from PubMed and the EMF-portal. The ODEB also includes military studies from the 70’s, biophysics research from the 80’s onwards, and all experimental and epidemiological research from both industry and independent scientists since 2012. The ODEB currently comprises over 4,000 peer-reviewed publications and is being continually updated.
The study then performed a literature search by requesting from ODEB all papers that used radiofrequencies > 6 GHz and exposure intensities below the International Commission on Non-Ionizing Radiation Protection (ICNIRP) limits. The result was a set of 295 papers containing all of the papers in the recent Karipidis et al. mmWave review, plus an additional 79 more experimental papers (nine non-English) and 19 more epidemiology papers (five non-English).
The study aimed to map out the entire landscape of research on the effects of 5G and mmWave technology, and to provide an overview of the existing mmWave evidence base. The study also examines how the science is being conducted and communicated, finding errors in reasoning that cloud judgements and the subsequent conclusions drawn from the existing research. The papers presented in the study can be used as the basis for future exploration using a more formal systematic review approach.
The study, by Oceania Radiofrequency Scientific Advisory Association (ORSAA), was looking for a wide range of bioeffects in the studies they reviewed as part of their examination of the existing mmWave evidence base. They looked at the number of studies showing effects vs. the number of studies showing no effects, regardless of the study design, merit, flaws, experimental quality, shortcomings, limitations, or methodological weaknesses. They mapped out the broader landscape by making visible the range of biological and health effect topics contained within the mmWave literature, such as:
- Effects on the cardiovascular system
- Effects on the nervous system
- Effects on the immune system
- Effects on reproduction and development
- Effects on the skin and eyes
- Effects on metabolism and hormone regulation
- Effects on cognitive function and behavior
- Effects on gene and protein expression
- Effects on cell and tissue damage
- Effects on cancer and tumor development
- Effects on the environment.
The Trend:
The trend is a limited amount of research on the effects of mmWaves (also known as millimeter waves) on biological systems, but the evidence that does exist suggests a range of potential health implications. The author argues that while scientists require strong evidence of causality before making definitive conclusions, policymakers need only moderate evidence to take action to protect public health. The overall trend suggests that there is a plausible risk associated with the use of mmWaves in 5G technology and that further research is needed to understand the potential bioeffects fully. The research highlights a difference in interpretation between scientists, who call for caution and further study, and industry-linked groups and organizations, such as the ICNIRP and the European Union, who have determined that the current evidence is insufficient to suggest any harm and, therefore, 5G rollout should proceed.
Standards being compromised
The issue of standards compromised in relation to the deployment of 5G technology and its potential effects on human health is a complex and controversial topic. One of the main concerns is the approach taken by the International Commission on Non-Ionizing Radiation Protection (ICNIRP) when setting exposure limits for 5G technology.
The ICNIRP is responsible for developing guidelines for the safe use of non-ionizing radiation, including the frequencies used in 5G technology. However, there are concerns that the ICNIRP has not adequately addressed the early evidence of biological effects that have the potential to cause harm. This has led some experts to criticize the ICNIRP’s radiation protection philosophy as deficient and not in alignment with that of the International Commission on Radiation Protection (ICRP).
The ICRP has a clear philosophy of radiation protection that is based on the principles of Justification, Optimization, and Limitation. Under this code of ethics, even mild evidence of harm would be enough to advise governments to give pause to the technology, to consider the potential risks, to commit funds to further research and to enact strict precautions.
This is not happening in the case of 5G technology, as the early message of plausible risk is not being heard, partly due to poor reasoning and partly due to poor communication. This is a serious concern as it means that the potential risks of 5G technology are not being adequately addressed, and the population is being exposed to potentially harmful levels of radiation without proper precautions in place.
There is an urgent need for further research to be conducted in order to fully understand the potential effects of 5G technology on human health. Until then, it is important that governments and industry leaders take a cautious approach, and consider the potential risks to human health before proceeding with the deployment of 5G technology. This means committing funds to further research and enacting strict precautions to protect the population from potential harm.
Standards being compromised in relation to the deployment of 5G technology is a serious concern. The approach taken by the ICNIRP in setting exposure limits for 5G technology is inadequate and not in alignment with the principles of radiation protection set by the ICRP. The early message of plausible risk is not being heard, and the population is being exposed to potentially harmful levels of radiation without proper precautions in place. It is crucial that governments and industry leaders take a cautious approach, commit funds to further research and enact strict precautions to protect the population from potential harm.
Logical fallacies in the communication of science
The communication of science is a crucial aspect of ensuring that the public and policymakers are informed about the latest research and findings in various fields. However, in some cases, the way in which this information is presented can be misleading, and logical fallacies can be used to distort the reasoning. Logical fallacies are errors in reasoning that can occur when arguments are presented in a way that is not sound or valid. They can be used intentionally to mislead or unintentionally as a result of simplifying the message for the public.
One example of a logical fallacy that is commonly used in the communication of science is the appeal to authority. This occurs when an argument is presented as true simply because it is made by an authority figure or expert in the field. While the opinions of experts should be considered when evaluating research, they should not be accepted without question, and the evidence presented in support of their claims should be evaluated critically.
Another example of a logical fallacy that can be used in the communication of science is the appeal to emotion. This occurs when an argument is presented in a way that is designed to elicit an emotional response from the audience, rather than to provide logical evidence. This can be done by using emotive language or by presenting information in a way that is designed to elicit a specific emotional response.
Another common logical fallacy is the strawman fallacy. This occurs when an argument is misrepresented or distorted in order to make it easier to attack. This can be done by exaggerating the position of the opponent or by misrepresenting their argument. This can be used to create a false sense of opposition and create an easy target.
Lastly, the ad-hominem fallacy is also frequently used in the communication of science. This fallacy occurs when an argument is rejected or dismissed because of the person making it, rather than the content of the argument itself. This can be used to discredit the opposing argument or to create an emotional response in the audience.
Logical fallacies are errors in reasoning that can occur when arguments are presented in a way that is not sound or valid. They can be used intentionally to mislead or unintentionally as a result of simplifying the message for the public. It is the responsibility of protection agencies, industry and researchers to ensure that their communications are clear and that fallacies are not inadvertently created when information is delivered to policymakers and to the public. It is important to be aware of these fallacies and to evaluate the arguments presented critically in order to make informed decisions.
Fallacies used in describing millimeter waves
In recent years, there has been a growing concern about the use of logical fallacies in describing millimeter waves (mmWaves) in communications related to 5G technology. These fallacies can occur unintentionally and can lead to misconceptions about the safety of these technologies. One such fallacy that is commonly used is the “Faulty Analogy” fallacy. This occurs when two things are compared in one or more ways but then an incorrect assumption is made that they are alike in other ways. An example of this is when government agencies or researchers introduce 5G technology as being based on mmWaves that are already in use in airport security screening. This can lead people to believe that 5G technologies are also harmless, when in reality, the two types of technology are dissimilar in several important ways.
Another fallacy that is commonly used is the “Red Herring” fallacy. This fallacy occurs when an irrelevant topic is presented in order to divert attention away from the main issue. An example of this is when mmWaves are introduced as if they are harmless for the human body, and it is stated that they do not penetrate more than a few millimeters into the skin. This diverts attention away from the more important issues of the mechanisms and biological functions of the skin. The facts that are ignored are that skin is rich in nerves that are connected to the central and autonomic nervous systems, and that it is the body’s first line of defense.
There is also a limited research on the bioeffects of mmWaves on the skin and the endocrine, neurotransmitter, and cardio systems to which the skin is connected. However, it is predicted from theoretical models that the skin’s sweat gland ducts (SGD) act as helical antennas, which can potentially carry mmWaves much deeper into the body. Furthermore, there are concerns that the rapid pulse trains contained within 5G signals will cause intense hot spots on the skin, resulting in permanent tissue damage and that the current ICNIRP guidelines do not protect against these hot-spots.
In conclusion, the use of logical fallacies in communications related to 5G technology and mmWaves can lead to misconceptions about the safety of these technologies. It is crucial for government agencies, industry, and researchers to ensure that their communications are clear and that fallacies are not inadvertently created when information is delivered to policy makers and the public. It is also essential for proper research to be conducted on the bioeffects of mmWaves on the human body before advancing to fifth and sixth-generation technologies.
Fallacies used in reviews
When reviewing mmWave studies, several fallacies can be present in the arguments used to critique experiential design and exclude certain papers. One such fallacy is the “Confusion of Necessary with Sufficient Condition” fallacy, which occurs when a study is acknowledged for reporting the necessary dosimetry, but the review does not ensure the inclusion of the more important sufficient conditions of the exposure, required to test the hypothesis. This means that studies with lower power are included in reviews and treated as if they are of high quality just because they reported the dosimetry. At the same time, studies with a higher power, that used real-world signals can be dismissed in the review because they do not clearly report the dosimetry.
Another fallacy present in reviews is the “Straw Person” fallacy, which occurs when the weakest points of an argument are attacked while stronger points are ignored. This fallacy can create a misrepresentation of an opponent’s position in order to make one’s own argument appear superior. Examples of the “Straw Person” fallacy occur in reviews that use less important issues as grounds to dismiss otherwise relevant and scientifically sound papers. For example, a lack of replication and inconsistencies between studies are often used to downplay the results of a study, even though replication is not always possible in the emerging field of mmWave studies.
Additionally, the term “poor methodology” is often used in reviews without a precise description of the flaw, making it difficult to determine the true impact of the flaw on the study. This can lead to accusations of serious methodological flaws when the issue is actually a minor one. Overall, it is important for reviewers to be aware of these fallacies and to avoid using them in their evaluations of mmWave studies in order to ensure that high-quality studies are not excluded and that the results of the studies are accurately represented.
Exposure principles confuse necessary and sufficient conditions
Quality studies on the subject of 5G and health need to report the dosimetry of the exposure signals clearly, including the frequencies used and the power densities or SARs measured. This is a necessary condition of good reporting, but it is not sufficient to guarantee that the exposures used in the experiment are adequate for testing the hypothesis.
One major issue with 5G technology is that real-world 5G signals are complex and variable. There are variable low-frequency pulses, control signals, pilot signals, and synchronization signals all being carried on the high-frequency 5G carrier waves. Additionally, to send multiple signals simultaneously, many 4G/5G technologies use Orthogonal Frequency-Division Multiplexing (OFDM), which requires extremely high peak amplitudes. These complexities in the waveforms cannot be fully replicated using simulated signals created by frequency generators. As a result, experiments that use real-world signals are more likely to produce effects than those that use simulated signals.
However, the type of exposure (to real-world devices/signals or to signal generators) is often ignored in the review process. Instead, a “Confusion of Necessary with Sufficient Condition” fallacy occurs, where a study is acknowledged for reporting the necessary dosimetry, but the review does not ensure the inclusion of the more important sufficient conditions of the exposure. This means that studies with lower power are included in reviews and treated as if they are of high quality just because they reported the dosimetry. At the same time, studies with a higher power, that used real-world signals can be dismissed in the review because they do not clearly report the dosimetry.
The importance of using real-world signals in experiments cannot be overstated. While highly controlled experiments are to be aimed for, they are not the highest priority if they prevent the experimenter from being able to test the stimulus that is creating the response, which thereby reduces the power of the test. Therefore, it is crucial that the exposure principles used in studies on 5G and health take into account the complexities and variability of real-world signals and prioritize the use of real-world signals over simulated signals in order to accurately test the hypothesis and ensure the highest quality research.
No replication or inconsistent results used to downplay results
It is important to note that replication and consistency of results are important factors in determining the validity of scientific findings. However, in the emerging field of mmWave studies, a lack of replication and inconsistencies between studies should not be used as a basis to downplay the results of a sound experiment. The complexity of available parameter combinations and the fact that all the studies are forging new ground means that a lack of replication and inconsistencies are to be expected. Additionally, funding bodies and universities do not typically fund replication studies, further contributing to the lack of replication in this field.
The use of the “Straw Person” fallacy, where the lack of replication is used as a means to dismiss the results of a study, is not only fallacious but also undermines the validity of the research. For example, in the case of two studies by a Russian research group that reported indicators of DNA damage in bacteria, the results have not been verified by other investigators, yet it is not fair to dismiss these results as invalid solely on the basis of lack of replication.
Furthermore, the use of “Collective Straw Person” dismissal, where a range of bioeffects are watered down by framing them as not yet replicated, also undermines the validity of the research. For example, Figure 1 shows a range of bioeffects, leading to the suggestion of considerable “smoke” that warrants further investigation of a possible “fire”, but if the range of bioeffects is watered down by framing them as not yet replicated, this undermines the validity of the research.
In conclusion, while replication and consistency of results are important factors in determining the validity of scientific findings, in the emerging field of mmWave studies, a lack of replication and inconsistencies should not be used as a basis to downplay the results of a sound experiment. It is important to consider the context and limitations of the research, and not dismiss findings solely on the basis of lack of replication.
“Poor methodology” has several meanings
The use of the term “poor methodology” in scientific research can be misleading and confusing because it can have several different meanings. In some cases, it may refer to a study that has a major flaw that compromises its integrity, such as the presence of a confounding variable. In other cases, it may refer to a study that has a minor flaw, such as noise factors or incorrect error bars, which may weaken the results but does not fully compromise the study.
This lack of precision in the use of the term “poor methodology” can lead to a logical fallacy of “equivocation”, where the meaning of the term changes throughout a review or discussion. For example, a review may state that “many of the mmWave papers have methodological flaws”, giving the impression that all these studies have major flaws, when in reality they may only contain non-major issues.
To avoid this fallacy, it is important for future reviews to classify methodological flaws into levels of seriousness, such as high, medium, and low, and to provide clear justifications for why each paper is classified as such. This will provide a more accurate representation of the quality of the research, and will prevent the confusion and misleading conclusions that can result from the use of the term “poor methodology” without proper context. Additionally, it will be important for future studies to replicate the research and to ensure that the results are consistent across studies to increase the credibility of the findings.
Non-linear dose-response misunderstood
The assumption that a linear dose-response relationship is necessary for radio frequencies is a flawed assumption and can lead to the incorrect dismissal of papers in reviews. This is due to a lack of understanding of the complex nature of biological responses to electromagnetic frequencies and the fact that feedback mechanisms and adaptive responses occur. It is important for researchers and reviewers to be aware of the non-linear nature of dose response and to consider the potential for non-linear relationships when evaluating studies. The credible evidence base for mmWave effects is likely to be larger than currently stated, and it is essential to avoid dismissing papers based on a misunderstanding of non-linear dose-response. Additionally, it is important to consider the potential for windows of power and frequency that can cause harm, as well as the non-linear response of the human perceptual system to electromagnetic frequencies. By recognizing the complexity of biological responses, we can move towards a more accurate understanding of the effects of mmWave exposure on human health.
Fallacies used in setting standards
The fallacy of “Slanting” is also present when ICNIRP and industry selectively choose studies that support their position, while ignoring or downplaying studies that present evidence of harm. This is especially concerning when the selected studies are industry-funded, as there is a potential for bias. Additionally, ICNIRP relies on the “Nocebo Effect” fallacy, which assumes that reported symptoms of harm are caused by psychological factors, rather than biological effects of exposure. This assumption undermines the validity of reported symptoms, and therefore the potential for harm.
In conclusion, the ICNIRP guidelines for radiofrequency exposure are based on fallacious reasoning and a lack of consideration for non-thermal effects, averaging, and potential biophysical effects. These fallacies have led to the underestimation of the potential harm from mmWave and other radiofrequency exposure. It is important for future guidelines to consider all available evidence, including non-thermal effects, and to recognize the limitations of averaging and the potential for biophysical harm.
Only heating matters fallacy
The “Thermal Only” fallacy is a problematic assumption that has been adopted by the International Commission on Non-Ionizing Radiation Protection (ICNIRP) and industry, stating that only heating can produce significant biological or health effects from exposure to radiofrequency (RF) radiation. This assumption is problematic because it disregards research that investigates non-thermal biological and health effects from RF exposure.
One area of research that has been impacted by this assumption is the study of millimeter wave (mmWave) effects on the skin. In the main mmWave literature review of skin effects presented within the current ICNIRP guidelines, the decision was made to focus only on heating effects, ignoring any non-thermal effects that may be present. This narrow focus on heating effects may lead to an incomplete understanding of the potential health effects of mmWave exposure.
Non-thermal effects from RF exposure have been observed in many studies, including changes in gene expression, cellular stress response, and oxidative stress. These effects may have significant implications for human health, and should not be ignored. It is important to consider both thermal and non-thermal effects when assessing the potential health risks of RF exposure.
In conclusion, the “Thermal Only” fallacy is a problematic assumption that has been adopted by ICNIRP and industry. This assumption disregards research that investigates non-thermal biological and health effects from RF exposure, leading to an incomplete understanding of the potential health risks. It is important to consider both thermal and non-thermal effects when assessing the potential health risks of RF exposure to ensure the safety of the public.
Averaging is not an adequate measure of harm
The use of averaging as a measure of harm in determining exposure guidelines for radiofrequencies, particularly mmWaves, has been widely criticized as a fallacy by many researchers. The International Commission on Non-Ionizing Radiation Protection (ICNIRP), a leading organization in the field, has been criticized for assuming that averaging over time and space is an adequate measure of harm without considering all of the available evidence.
The use of averaging in determining harm assumes an underlying normal distribution, which is not the case for complex telecommunications signaling. Averaging can hide potential biophysical effects, resulting in a conclusion of no harm overall, even though extreme harm may have occurred for a small portion of tissue. This is a problem because it can lead to inaccurate conclusions about the safety of exposure to radiofrequencies and can ultimately put individuals at risk.
For example, averaging over time and space can hide the potential for extreme harm in certain situations. For instance, if an individual is exposed to a high level of radiofrequency radiation for a short period of time, averaging the exposure over a longer period may result in a conclusion that the exposure was safe. However, the short-term exposure may have caused significant harm to that individual. Averaging can also hide the potential for harm in certain locations or for certain groups of people. For example, if a group of people are exposed to radiofrequency radiation in one location, but only a small portion of them experience harm, averaging the exposure over the entire group may result in a conclusion that the exposure was safe.
In conclusion, the use of averaging as a measure of harm in determining exposure guidelines for radiofrequencies is problematic because it can hide potential biophysical effects and ultimately put individuals at risk. It is important that all available evidence is considered when determining exposure guidelines, rather than relying on averages that can be misleading. The ICNIRP and other organizations should consider alternative measures to ensure the safety of individuals exposed to radiofrequencies.
Authority uncertain
The fallacy of “Appeal to Authority” is a common one that occurs when claims are believed because they are made by alleged authorities, without considering whether the authority is truly an expert in the field, if they are presenting facts that are widely agreed upon, or if they can be trusted. This fallacy is particularly relevant in the context of radiofrequency safety, where bodies like ICNIRP and the WHO International EMF Project have been given formal authority on the issue. However, many researchers have criticized these bodies for being a small self-referencing group with no dissenting voices, and for presenting a consistent message that there is no evidence of harm from radiofrequencies, including mmWaves.
One important issue to consider when evaluating the authority of experts in this field is the potential for industry influence on their research. Many scientists researching in this field have links with industry, and therefore conclusions from their papers need to be treated with caution. For example, industry-funded research for UHF studies has been found to typically use short-term, single one-off exposures, to predominantly expose cell lines rather than live animals, and to avoid epidemiological studies. These design decisions have resulted in studies that do not provide insights into potential health effects associated with multiple long-term, real-world exposure scenarios.
An analysis of mmWave studies also demonstrates how industry funding can influence outcomes. Industry-funded mmWave studies have produced a lower overall proportion of “Effect” outcomes, compared to government-funded and institution-based studies. This highlights the need for caution when evaluating the authority of experts in this field and the importance of considering potential sources of bias when evaluating research on radiofrequency safety. It also underlines the need for independent research that is free from industry influence.
In conclusion, the fallacy of “Appeal to Authority” is a common one that occurs when claims are believed because they are made by alleged authorities, without considering whether the authority is truly an expert in the field, if they are presenting facts that are widely agreed upon, or if they can be trusted. In the context of radiofrequency safety, bodies like ICNIRP and the WHO International EMF Project have been given formal authority, but their authority should be viewed with caution, as they are criticized for being a small self-referencing group with no dissenting voices. Furthermore, scientists researching in this field may have links with industry, which can influence their research and conclusions, making it imperative to consider potential sources of bias when evaluating research on radiofrequency safety and to support independent research free from industry influence.
Conclusions
In conclusion, the potential long-term health risks from global exposure to electromagnetic fields (EMF) are a cause for concern as exposures in the built environment continue to increase in time and density. The rollout of 5G technology, which utilizes new radiofrequencies, has been based on a lack of understanding of the impact of these frequencies on long-term human and planetary health.
The evidence presented in this essay suggests that there are credible risks of biological interference effects for frequencies planned for 5G, occurring well below the reference limits set by ICNIRP. Given the ubiquitous and often non-consensual nature of man-made wireless radiation exposures, the presence of even a small number of significant bioeffects requires further research.
The communication of existing investigations into the health risks of EMF has not been fully clear or transparent. It is the responsibility of government review panels, regulatory bodies, scientists, public advocates, industry, and policy makers to clearly communicate the research and its implications, so as to ensure that no fallacious conclusions can be drawn.
The mmWave evidence base suggests that plausible health effects cannot be ruled out, and that urgent action is needed on two fronts: further sound scientific research, done carefully, using the best laboratory practices and sufficiently large samples to produce significant results, funded and overseen by trusted bodies with appropriate expertise; and precautionary actions to be taken by policy makers via use of risk aversion strategies such as the actions recommended in an EU commissioned report. The limitations of scientific knowledge imply a moral responsibility to take precautionary action in order to avert harm.
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