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Introduction - Opening Arguments 1. The entire NRPB Consultation document is presumptively based on a serious logical flaw. The present guidelines, standards and limits being adopted in the West are based on bad science, and influenced by commercial not biological considerations. To disguise this the NRPB Con Doc fails anywhere to mention or discuss the permitted exposure limits ("PELs") adopted in China and the Eastern bloc, representing about 25 per cent of the world's population, and based on careful biological/physiological studies available in English to the authors of NRPB Con Doc. 2. The underlying basis for the NRPB Con Doc's higher frequency Investigation levels is the Specific Absorption Rate ("SAR"). This concept is not soundly based in science, but relies on artificial, inaccurate models mainly devised and conducted by consultants in the pay of commercially or militarily involved parties, faulty mathematics, and a handful of dubious animal experiments carried out by one selectively biased laboratory decades before the advent of mobile telephony. 3. The NRPB Con' Docs power frequency (extremely low frequency or ELF) investigation levels are designed to avoid impact on existing high voltage powerlines and are not self consistent. They too fail to mention or discuss the hundreds of studies being reported in the literature of adverse effects at levels well below the so called thermal levels (i.e. the level at which the power is so great it begins to burn you). They omit many important peer reviewed studies reporting adverse effects at well below the proposed levels. 4. The NRPB Con Doc was compiled by a handful of people most of whom are not very well qualified in biology or in non-ionising radiation discipline, whose jobs depend on commercial interest funding, and who are linked in a small network of European scientists of the same mainly negative view of likely health risk. There are no independent scientists among the authors, naturally, since all are members of the NRPB staff. An appendix by the Weak Electric Fields Group ("WEFG") shows that the three academics involved in it have virtually no direct bioelectromagnetics background either, but at least they have the correct skills and may be looking in the right direction for eventual standard setting.. 5. As well as fundamental errors of omission there are so many errors of commission and misinterpretation of reported studies as to raise the question of serious scientific misconduct. This view is not ours, but was argued in a 1990 JAMA article (Chalmers, 1990). SUMMARY of this REVIEW 1. It is an absolute nonsense that any document setting forth proposals for EMF standard setting should fail to discuss or even report the standards already in place in other significant parts of the world, nor even examine their constructional or biological bases. Yet this is precisely what the NRPB Con Doc does. There is nowhere any mention of the EMF permitted exposure limits in place in the Eastern bloc countries, which largely follow the standards set by the former Russia. A historical review of how the USSR RF standards were derived (Gregoriev, et al., 2002) is therefore included within this critical review, and we ask that NRPB frontally address its factual results and the conclusions to which they have given rise. An anglicised version of Gregoriev's paper is found here. The derivation of ELF EMF standards was reviewed by Shandala et al., in 1988 in Andy Marino's comprehensive compilation Modern Bioelectricity (1988) and was inevitably available to the authors of the NRPB Con, yet it is also nowhere referred to. This kind of deceptive omission not only introduces serious doubt in the public mind over the fitness of the NRPB to engage in standard setting (which will no doubt be enjoyable alimentation for the media) but raises the question whether such deliberate wilful omissions by experts purporting to carry out a protective function on behalf of the public constitute criminal neglect. The same criticism applies to the Chinese standards and the bases from which they arise. There is absolutely no excuse for this major and deliberate omission: the Chinese standards and their biological derivation were published in two separate papers in English (Zhao et al., Reviews on Environmental Health 10(3-4): 209-212 (1994) and Reviews on Environmental health 10(3-4): 213-215). Zhao and colleagues are from Beijing Medical University's Department of Occupational Health. My overview of the crucial Chinese experiments which led them to accept non thermal effects and embody them into their 1994 permitted exposure limits is found here. So let us look at these various Western standards and the (dubious) extent of their basis in biology. The three main Western guidelines (not standards) are from ANSI, ICNIRP, and NRPB. The first thing to notice is that there are substantial differences between them, so who is correct?! LOWER FREQUENCIES UK exposure guidelines for low frequency (under 100kHz), though in four bands, are of principal interest at 50 Hz (power frequencies), so we will confine comparisons to these, the basic restriction for which for magnetic fields is 10 milliAmperes/square metre, and for electric fields the investigation level is 12000 Volts per metre, just a little above what might be found under the midspan of a large powerline. For magnetic fields the UK investigation level is 1600 microTesla at 50 Hz. but this is many times the 40 microTesla magnetic field at the same place. Both are given as at rms values. An estimate of the current density (J) induced by a low frequency magnetic field can be derived from ¦J¦ = sprBo where s is the conductivity, r is the radius of the closed current path, and Bo is the applied magnetic flux density. Using a conductivity of 0.2S/m and a radius of 0.2 metre gives the present current density restrictions. (This works out at 11.3 milliAmps per square metre). Using the same conductivity for the electric field J = s* E , where s* = s + iew, where e is the permittivity and w is the radial frequency. In a plane wave relationship there is a fixed equivalent electric and magnetic field strength, so that for example an electric field strength of 6.14 V/m is equivalent to a magnetic field of 16mA/m, the power density being 0.1 W/m2 and the equivalent magnetic flux density being 0.020microTesla. The unifying formula is S = E2/377=377H2. where S is the power density, the impedance in free space is taken to be 377 Ohms, and H is the magnetic field strength in A/m. But the investigation levels are not self consistent, since 120002 V/m/377 (381962) does not equal 377 x 12802 A/m (617.7 million). Admittedly these measures are in the near field, but the investigation levels are still not self-consistent. To be so the magnetic field would have to be lowered to around 32 A/m or 40 microTesla, which is much lower than the field a few centimetres from many domestic electric appliances or near electricity substations. it almost seems as if the investigation levels were so arranged to be just a little above these exposures. Nor are they consistent with the ICNIRP guidelines (termed "reference levels", - or the ANSI recommendations for that matter). The ICNIRP reference level for electric fields is 10,000 V/m and for the magnetic flux density at 50 Hz a mere 100 microTesla! Perhaps that is why the NRPB Doc seeks to adopt the ICNIRP levels (para 556, page 112). This proposed overnight 16 fold reduction in the magnetic field investigation level will not have a comforting effect on the public, who must wonder, if the NRPB got it so wrong before now, whether they have yet got it right, since even now there is a basic inconsistency between the electric and the magnetic investigation levels when the far field formula is applied. The basic restrictions aim to be just below the perception threshold, at which for example the hair on one's skin stands up. This makes the illogical assumption that only when we perceive the fields are they likely to be harmful. There are however many studies reporting effects at ELF frequencies far below 120000V/m, and this has been conceded by NRPB for more than a decade. A distinction must be made between an effect and an adverse effect. So how strong is the evidence for adverse effects at weak field strengths? The issue is addressed by the Weak Electric Fields group, whose Appendix appears at the end of the NRPB Con. It is in my view a very incomplete Appendix, and I discuss it in this subpage. HIGHER FREQUENCIES Turning to the higher frequencies, the central issue is that of the specific rate of energy absorption by living tissues ("SAR"). This concept demands that one believes that only the amount of energy absorbed into the body is going to have any biologically adverse effect, and this may be a fundamentally wrong approach. SAR is defined by the conventional formula SAR (in Watts per kilogram of tissue) = s¦Erms¦2/r where s is the conductivity, E is the electric field inside the body, and r is the tissue density of interest. This is complete pseudoscience. First we must realise that all organs - indeed all cells - are bathed in a highly conductive saline solution which effectively unifies the whole body and permits electrical signals to pass directly and almost without loss of strength at much faster speeds than nervous conduction to cells from (e.g.) the brain's rhythms and the heart's beat. Any incoming perturbation of these delicate signals is going to have an effect on their signal to noise ratio. Individual tissue densities inside their epithelial membranes are irrelevant, since the fastest conductivity is what counts. This has been evidenced since the first days of high voltage powerlines, when workers reported effects from levels lower than those offered here on their heartbeat rates after working in 750kV Russian switchyards. Moreover, when it comes to calculating SAR there are so many variables and measurement protocols that not only do different time periods and different masses or organ sizes affect the results, but even the slightest repositioning of the source has a massive effect on the SAR a few centimetres distant. Internal electric fields from the brain and heart can be actually lower than those induced artificially, suggesting a high noise or disturbance level to vital life processes. A detailed argument about the ridiculous notion of using SAR as a measurement for standard setting is given here. More than that. Even if SAR were an acceptable metric, the experimental basis for choosing the level of 4W/kg is also complete scientific gobbledegook. It was arrived at by averaging a few short-duration exposure experiments on monkeys and rats where their short term responses were deemed to equivalate to long term effects on human beings. Other animal studies on longer tem effects from much lower exposure levels were excluded, but if all the relevant experiments were averaged (a dubious premise in any case) the limit would need to be lowered to a third of the present values! This would make it impossible for cellphone handsets to comply. For a more detailed exposition of this foolish saga click here. More than that, too. There are important differences at say 2 GHz frequency between the ANSI, NRPB (10W/kg for any 100 grams of tissue in the neck or trunk averaged over a 6 minute period) and ICNIRP (2 W/kg for any 10 grams of tissue in the neck or trunk, averaged over a six minute period) investigation/reference levels. Which one if any is correct?! Recognising the stupidity and lowered credibility of such disparities the WHO is mounting a programme to unify the various standards, guidelines and limits, so the NRPB Con Doc aims to bring its advice more into line with the ICNIRP levels. Unfortunately they are both wrong. But the first and primary issue in considering the NRPB Con Doc is that it is balanced precariously on a single major logical fallacy. This is the presumption that standards should be set to reflect threshhold perception (i.e. at the lowest conscious level of perception by an individual). This as great a fallacy as to set the permitted exposure limits for carbon monoxide at the level at which one can first smell it. It runs completely counter to all environmental science. What the NRPB Con Doc asks us to accept is in the case of weak electric fields the standard should reflect the point at which the exposee perceives electromagnetically induced phosphenes originating in the retina. Beyond this gross error it also predicates that the retina is a suitable vehicle for standard assessment because it is peripheral to the body and contains receptor cells honed by evolution to distinguish electromagnetic energy at visible light frequencies. Both these arguments run counter to physiology, the first for the simple reason that exterior body surfaces have developed protective processes (e.g. the layers of dead skin cells which offer a physical barrier to insults), and the second that the penetration by EMFs into the body's interior inevitably encounter organs unprepared by evolution for their influence. If physiology is to be any guide in standard setting, then the effects on the weakest, most unprepared organs of the body should be a starting point, not those well habituated to exterior events. The easiest lessons of radio science tell us that a radio receiver for one frequency will not "perceive" another frequency for which it was not tuned. 4. We alleged in our Opening Arguments that the NRPB Con Doc was compiled by a group of people most of whom are not very well qualified in biology or in non-ionising radiation discipline. This may seem an astonishing allegation, since the NRPB Con Doc authors are all NRPB staff members, and even the mysterious "Weak Electric Fields Group" ("WEFG"), which seems to have emerged in 2001 fully grown from out of nowhere, includes three external Professors as well as three of the usual suspects. If one defines the words well qualified as having a Doctorate in Biological Sciences, then how many of the ten authors have this? If one defines non-ionising radiation discipline as being a member of either the European Bioelectromagnetics Association or the Bioelectromagnetics Society (preferably both, since their meetings do not substantially overlap in contributor content), then how many of the ten authors are such members? I do not cast any doubt on the personal integrity or intelligence of the NRPB Con Doc authors, nor do I allege they are unfamiliar with the literature, but am simply concerned with their mind set, which, despite the fundamental change embodied in the NRPB Con Doc, is still largely imbued with traditional NRPB thinking. The Weak Electric Fields Group As for the WEFG, how much does Colin Blakemore know about bioelectromagnetics science? The skills which may have earned him a place are those of science communicator rather than expert. I think we have a better chance with the other two Professors, particularly John Jefferys, whose neurophysiology lab at Birmingham University's Dept of Neuroscience is involved in understanding brain function, and particularly the way alternating ion flows between the cerebral pyramidal cells send rhythms into the rest of the body. This means he is thinking about the delicacy and purpose of those coded signals and how they may be interfered with by induced electric fields to which induced electric currents give rise. That is the right mindset. Some 15 years ago, based on studying the neuropathology of sudden infant death syndrome, where corpus callosic demyelination follows exposure to EMFs in the largely unmyelinated infant brain, I put forward an hypothesis based exactly on the effects of EMFs on that process, as well as defining how the brain's structure and energy was constructed to send electric fields of astonishing elegance into the CSF for the purpose, I argued, of regulatory control. The paper was accepted by Medical Hypotheses at the time I recall, but I did not feel it was complete enough to publish. My hypothesis eventually appeared in the peer reviewed literature in 2000 (Coghill and Galonja-Coghill, 2000), after I had finally gotten testable experimental support for the notion, and was satisfied that the paper would be a pivotal one for biology. The two diagrams here appeared in an article I wrote for J Alt Comp Med (UK) in October 1988, but that was hardly a peer-reviewed journal! When Jefferys has had time to think about all this he may come to the conclusion that my hypothesis about this cerebral apparatus is a fundamental new insight into brain function, and should be considered when setting EMF exposure guidelines. Perhaps meanwhile he might join BEMS or the EBEA to get a better handle on the science, and should also get boned up on Jiri Pokorny's work, because their list of references in Appendix A is woefully inadequate and omits many of the important and relevant studies in this field. The third Professor in WEFG is David Attwell from UCL at Gower Street not a million miles from the London School of Hygiene and Tropical Medicine, where Prof Michel Coleman might tell him a few things about EMF epidemiology over lunch. Attwell's group is also investigating brain energetics and the vital work relevant here is that "Theoretical calculations suggest that much of the brain's energy is employed in reversing the ion movements producing synaptic currents and action potentials" (Attwell & Laughlin, 2001). So between the two of these professors this WEFG may at last be looking in the right direction: the brain uses most of its energy to alternate the ion flows between the pyramidal cells so as to create electrical signals travelling ubiquitously via the CSF to each individual cell. That is why the brain, an organ of about 2 percent of the total body weight, consumes 30 odd percent of the oxygen we breathe and uses it to create some 20 percent of the body's energy, without having a single muscle! The brain is in reality a transmitter with the Corpus callosum as the "radiating" antenna, constantly transmitting regulatory codes to the body's 140 trillion cells, (but most importantly during REM sleep when the signal to noise ratio is optimal). This code needs to be cracked, but we got some way down that road by showing in our 2000 study that it is unique to every individual, just like DNA, and we speculated there must be a direct connection between the brain's rhythms emitted during REM sleep and DNA, so the prize is getting nearer. Since electric fields are superpositive any induced electric field in the body interior, wherever arising, is going to interfere with existing signals, and these professors know that. Accordingly tissue conductivity (especially that of the retina) is an irrelevance, since it is the body's bathing fluids which determine interference. I shall deal with this issue in more detail when discussing SAR. We found in our lab that the highly conductive saline solutions in the body will carry any signal everywhere, which is what Nature intended in a world devoid of modern technology and its attendant fields and radiations. These artificial EMFs are completely novel ton to evolution. All these professors now need to concede is that the electric fields induced by EMFs at non thermal levels are sufficient to cause that interference, and we will then at last have a proper basis for standard setting. Unfortunately the NRPB Con Doc is still riddled with traditional thinking, and so incomplete in terms of the references it quotes that such a conclusion is not overt. There is a strange but telling sentence at the outset of the NRPB Con Doc "This report from NRPB reflects understanding and evaluation of the current scientific evidence as presented and referenced in this document"(my italics), hinting that they know they have left out important evidence. The professors should make their own independent reviews and not rely on being fed by the usual NRPB suspects (as was Willie with the references supporting traditional thinking. This review will help them do that. As it stands however, the only changes being proposed in the NRPB Con Doc are to halve the occupational exposures to 5 W/kg, which frankly is simply cosmetic. The vital U-turn however has at least been made in this document, and AC electric fields are at last being recognised as the proper metric, not the AC magnetic fields foisted upon bioelectromagnetics research by EPRI and the power utilities over the years. EVIDENCE OF BIAS 1. The issue of free radical effects on chemical reactions (see para 95, p19): The NRPB Con Doc authors refer to Bob Adair's 1999 paper refuting free radical formation as a possible mechanism of weak field interactions, but entirely omit to reference Keith McLaughlan's original Physics World paper "Are environmental magnetic fields dangerous?" which started that debate and caused an uproar in the bioelectromagnetics community. It is a misrepresentation to present Adair's 1999 paper as "a discussion of these mechanisms" when it is simply a statement of his not very well accepted own views. Adair concludes his 1999 paper with the words: "Hence we conclude that it is highly improbable that external magnetic fields as small as the earth's field of about 50microTesla can affect biology through modification of the probability of recombination of radical pairs, and we conclude that effects from fields as small as 5microtesla are improbable". Essentially McLaughlan a Fellow at Oxford University's Chemistry faculty found in 1992 that very weak magnetic fields could affect chemical reactions with no lower limit to the exposure level, and argued that because of this one could not rule out the possibility that they affected biological processes too. Bob Adair is an aging Yale physics professor who has long had the gall to face upto hostile bioelectromagnetics audiences with the view that bioelectromagnetics science is largely " bum theory and bum data". He performs a valuable service as devil's advocate and is respected for it, but it is arguably misconduct by NRPB Con Doc authors to omit the arguments against which he is positioning himself. They only reference McLaughlan's innocuous 1981 and 1996 papers (the latter co-authored with Brocklehurst) on the same subject. It doesn't take much to see why. The temporary boldness of McLaughlan in 1992 was embodied in his final telling conclusions: "Finally, we might point out that the levels of exposure deemed safe for workers and the general public are based upon little hard fact. They were drawn up before most people realised that fields can affect chemistry, largely in an atmosphere ignorant of whether fields interact with biology or not, and largely by looking to see what magnitude s of field are commonly experienced in different professions, without apparent ill effect. "Fields are ubiquitous in the environment, and are widely used in industry and in magnetic resonance imaging in hospitals. The vested interest in believing them to be harmless is enormous. The work reported here at least suggests that this conclusion may be over-hasty". The issue was featured in a 1994 Panorama programme not pleasing to McLaughlan, and even less to the powers in his University corridors. So in February 1994 McLaughlan issued a written recantation on Oxford University notepaper, where he continued to enjoy his tenure more quietly thereafter. Having done his duty, like Galileo Galilei, he nevertheless wrote in the same letter that "What we have been able to show is that a class of chemical reactions used by the body can indeed be affected by low magnetic fields, and the implications must be that those occurring in the body are similarly affected". The NRPB Con Doc authors bury this whole important and highly technical discussion in their section on static magnetic fields, but McLaughlan's 1992 paper implicated time-varying fields which are ubiquitous in modern society, saying "there is likely to be a range of frequencies which affect the behaviour". The essential difference to remember between these two men and their arguments is that Bob Adair's work is theoretical while McLaughlan's is practical. Anyone familiar with cell metabolism will also know that it depends on free radical transients (ubiquinone->ubisemiquinone->dihydroubiquinone) to achieve satisfactory oxidative phosphorylation, and that cancer cells appear to have lost this capability, being restricted mainly to glycolytic pathways. If alternating magnetic fields can affect these essential metabolic radical processes at a very weak level, then cancer might well result. 2. The issue of induced electric fields in the human body (see pp52-57, paras 241-255) Almost at its outset (paras 50-57, p9) the NRPB Con Doc plunges into dosimetry and the issue of the internal electric fields and current densities induced inside the body by external artificial fields and radiations from powerlines, RF/MW masts and the like. In fact the whole basis for its exposure restrictions/guidelines on exposure to ELF electric and magnetic fields, according to its position statement in 1993 (Vol 4(5), para 9 p2) was "intended to avoid the effects of induced electric currents on functions of the central nervous system such as the control of movement and posture, memory, reasoning, and visual processing". These early paras simply describe the four main research groups working on human phantoms, namely Om Gandhi's group at Utah, the Brooks Air Force base group, Maria Stuchly's group at Victoria, Canada ("Uvic"), and the NRPB's own phantom "NORMAN" developed by Dimbylow. They all use different body weights and different sized voxels or millions of small boxes labelled with the estimated tissue conductivity at that place in the body. These "boxes" not only differ in size between groups, but also use differing conductivity values for various tissues, so not unnaturally they each arrive at quite disparate answers on the question of what current density or electric field might be induced from a specific applied field. The difference can be upto around 40 percent between models, and there have been great efforts to explain why this should be, because obviously such a level of disagreement must cast doubt on the level of exposure restriction derived from it. Part of the answer seems to be that the smaller the box size (e.g. Gandhi uses a 6mm box side, Uvic has a 3.6mm, while NRPB has a 2mm side) the higher the values are often calculated. Hence for the whole body NORMAN finds a maximum of 82.2A/m-2 while Uvic only finds 63.7 at 50Hz. The model calculations can be based on a grounded or an isolated person in the field, e.g. whether or not you are wearing wellies or in bare feet under the powerline of interest. On p 50 (para232) NRPB Doc returns to dosimetry saying that "Current UK guidelines provide basic restrictions on induced current density to prevent effects on CNS functions for frequencies upto 10MHz", a restatement of their 1993 position. They go on to compare the various results of the four groups, but to make the comparison recalculate the induced current values based on an applied field of only 1 V/m-1, a field strength so low you would be lucky to find it in an open field in the depths of the country (most homes will have places at least ten times that value). As a result the current densities presented from a 1998 paper by Cynthia Furze and Om Ghandi seem well within the ICNIRP guidelines of 10mA/m-2. But by doing that NRPB Con Doc completely misses the point of Cynthia Furze and Om Gandhi's 1998 results to which they refer, and which are based on a 6mm "box" resolution size. These authors took a field strength of 10kV/m, not 1V/m, this being the 1990 exposure limit proposed by IRPA and in 1995 by CENELEC, and the kind of field one might find oneself in directly below the midspan of a large high voltage powerline. (In passing I point out this is 20 percent less than the NRPB's own present UK exposure guidelines). The concerning conclusions made by Furze and Gandhi (1998) is that when one compares the normal endogenous current densities induced by the beating heart at various parts deep in the body's interior such as the brain, the pineal gland and the thalamus with the exogenous current densities induced by 10kV/m powerlines, the artificially induced fields were many times higher: for the pineal gland, where melatonin is synthesised, the average endogenous level of 6J compared with 1451J from the exogenous 10kV/m source. Local current densities of as high as 20mA/m-2 induced by these powerlines are found in the head and trunk, with even much higher values (above 150mA/m-2) in the legs. Trying out various realistic combinations of electric and magnetic fields they discovered that the vertical electric field coupled much more strongly than the horizontal magnetic field. This makes it important to conduct electric rather than magnetic field studies, a direction that funding agents like EPRI and the National Grid's EMF Biological Trust seem reluctant to take. (Even the recently reported UKCCCR study almost did not include electric fields, but only as the result of intense pressure on Sir Richard Doll in 1990 from this laboratory). The implications of Gandhi's findings are that HV powerlines, let alone other EMF sources, can introduce into the body levels of current density far higher than those used physiologically for life processes. For example, the heart's electric field at the sino atrial node controls the heart beat rate and I suspect also vasculatory muscular contraction, so interfering with that signal should show up in altered heart beat rate. This (bradycardia) is precisely what early Russian studies (e.g. Asanova and Rakov, 1972) reported among workers in their high voltage switchyards, but the validity of which the NRPB (and the UK National Grid) has ever since tried strenuously to deny. Some would even argue (Chalmers, 1990) that by underreporting the situation it borders on scientific misconduct in that the NRPB Con Doc nowhere mentions Furze and Gandhi's important conclusions (so far as I can yet see) in their document, but merely makes a deceptively academic comparison between the models from which the public lay reader might draw comfort. I will return to this topic in due course. 3. Has epidemiology has been steered away from electric field studies? When a large Canadian occupational study conducted by Theriault and other scientists at McGill University, and using utility workers from Canada and France as the target group, announced a strong association between cancer and the electric component of the exposure, their data was withdrawn from them for a number of years, and they were forbidden to discuss it or analyse it further. It would seem that the world's utilities are very sensitive about electric field effects. One might say, almost flippantly, that everyone has heard of electrocution, thanks to the use of that barbaric method of executing criminals for a over a century in the US, and numerous examples of injury and death from domestic and industrial electrical accidents . But who has ever heard of magnetocution?! If any British householder asks his local electricity company to measure the fields in his home, the company will never measure the electric fields. This smells of suppression. It would be a simple and costless matter to place warning signs on electric appliances such as electricity meters so that residents do not sleep too near them. For a detailed exposition of how the electric field has been excluded from epidemiological studies or so badly collected as to be meaningless click here. CONCLUSIONS The Precautionary Principle: a pickled pepper? A forthcoming book by Pat Thomas "Living Dangerously" takes the words out of my mouth: "The Precautionary Principle acknowledges that the nature of what is considered scientific evidence has to change. In these days, we must take into account all kinds of data, classical studies, case reports, consumer complaints and more - to arrive at reasonable conclusions. "When assessing the harm done by environmental toxins many Government agencies use what is known as 'risk analysis' to calculate levels of acceptable risk. Indeed, the idea of acceptable or low risk is enthusiastically sold to the public as a good reason to continue exposing ourselves to certain toxins, such as radiation or heavy metals. "In addition, when potential hazards are addressed by Government agencies, they are usually addressed one at a time, even though none of us is ever exposed to pollutants one at a time. Broader issues, such as the need to promote organic agriculture, to de-escalate our addictions to shopping and acquiring consumer goods, to encourage the use of non-alcoholic products and to phase out whole classes of dangerous chemicals are also rarely addressed. "To overcome these barriers requires new thinking about the nature of 'evidence', but also about effective means of protection. In response to this need, a sophisticated version of the old adage "better safe than sorry" has evolved. Known as the Precautionary Principle, it is based on the idea of 'forecaring', and the knowledge that science because of its limitations and uncertainties, is simply not able to provide an accurate prediction of future hazards. The Precautionary Principle does not call for an abandonment of science. Instead it suggests we: take action, even in the face of uncertainty place the burden of proof of relative safety or harm on the proponents of an activity rather than on the potential victims explore alternatives to possibly harmful actions use democratic processes, including decision-making that involves the views of those most affected. "With risk analysis whatever can't be quantified, (that is reduced to a numerical, statistical risk factor) is simply taken out of the equation as unimportant. But doing so creates large gaps in our understanding, and gives big corporations and government agencies a good excuse to continue moving forward with actions that may well be harmful to health". What can one man do against the State Machine? Cry out and loudly. Involve the world and the public at large in his better insights; but above all record in detail, for all to see and understand, the errors of these saline pillars of society. I hope this review does just that. Accordingly, I would ask the NRPB to address all the points I have made in this presentation and its subpages, and to give permission for their response to be included or linked to this site. top |
