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Prof. Girish Kumar's comments on "DOT Report for Allahabad HC" on EMF Radiation and Health
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Prof. Girish Kumar's comments on "DOT Report for Allahabad HC" on EMF Radiation and Health

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Prof. Girish Kumar's good work on Cell Phone and Cell Tower Radiation Hazards is being sidelined by telecom representatives and the facts are being twisted. …

Prof. Girish Kumar's good work on Cell Phone and Cell Tower Radiation Hazards is being sidelined by telecom representatives and the facts are being twisted.

In this report Prof. Girish Kumar's has summarized his comments in blue colour.

Prof. Girish Kumar's comments ON Report of the Committee Constituted as per direction of Hon’ble High Court Allahabad, Lucknow Bench in its order dated 10.01.2012 in writ petition No. 11275 (M/B) of 2010
ON ISSUES RELATED TO EMF RADIATION

Highlights:

- Prof. Girish Kumar' calculations are twisted by the commitee and presented wrongly.

- They have forcefully written "Prof. (Dr.) Girish Kumar has agreed that all these factors have not been considered in the calculations given by him".
> However the truth is - He did not agree with the committee but they chose to write for the reason best known to them.

- They have mentioned "currently there is no CONCLUSIVE scientific evidence which establishes that EMF has harmful non-thermal effects".
> However Prof. Kumar has repeated presented the BIO-INITIATIVE report 2012 which has given references of 3800 scientific research papers but committee chose to ignore all the time due to reasons best known to them.

- They have mentioned "so far, no conclusive evidence on adverse health effects by EMF radiation from mobile handset has been found internationally by World Health Organization (WHO)."
> No conclusive evidence does not mean no evidence. WHO accepted cell phone as possibly Carcinogen in 2011, where as earlier they had not classified as Class 2B. The reason is that radiation hazards are cumulative in nature and as usage is increasing with time, larger number of people are reporting health hazards.

- They have mentioned "In order to implement the EMF radiation norms, DoT has prescribed a procedure to be followed by the telecom service providers. To oversee the implementation, DoT through its 34 field units, known as TERM units, takes self-certificates for compliance of EMF norms by the operators and conducts regular audit of the EMF radiation exposure from the mobile towers as per the prescribed procedure".
> Self certification is not good. Also, audit of only 10% of sites is done

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  • 1. Page 1 of 70 Government of India Ministry of Communications & Information Technology Department of Telecommunications Report of the Committee Constituted as per direction of Hon’ble High Court Allahabad, Lucknow Bench in its order dated 10.01.2012 in writ petition No. 11275 (M/B) of 2010 ON ISSUES RELATED TO EMF RADIATION
  • 2. Page 2 of 70 Report 1. Introduction : Hon’ble High Court Allahabad, Lucknow Bench in order dated 10.01.2012 in writ petition No. 11275 (M/B) of 2010 in the matter of Shri Ram Singh Jauhari Vs UOI & Others issued following direction: “ We direct the Government of India to constitute a Committee of five members of Electrical Engineering Department of the IITs of Mumbai, Kharagpur, Kanpur, Delhi, Roorkee including Prof. (Dr) Girish Kumar and four other prominent persons of other scientific institutions of the country like AIIMS (Delhi), Indian Council of Medical Research etc to submit a report so that the Government of India may take necessary precaution while granting permission for establishment of mobile towers as well as to regulate sales of mobile with necessary precautions.” In compliance of above court order, a committee was constituted vide DoT letter No. 17-63/2011-CS-III Dated: 20.08.2013. Nominations were asked from the heads of the respective organizations. Based on the nominations received from IIT Mumbai, IIT Delhi, IIT Kharagpur, IIT Kanpur, IIT Roorkee, AIIMS Delhi, Indian Council of Medical Research New Delhi, Indian Institute of Toxicology Research Lucknow, Science & Engineering Research Board (SERB) under the Department of Science & Technology (DST), members have been included in the Committee. Further, Department of Telecom has nominated four officers working in the field of EMF Radiation. Following is the constitution of the committee, consisting of thirteen members: 1. Shri S. S. Sirohi, Senior Deputy Director General (Telecom Enforcement, Resource & Monitoring – Term) (TERM) DoT – Chairman 2. Dr. (Prof.) Ajoy Chakraborty, Professor, Department of Electronics & Electrical Communication Engg, IIT Kharagpur, --Member 3. Dr. (Prof.) Ajit Kumar Chaturvedi, Dean of Research & Development, IIT Kanpur, -- Member
  • 3. Page 3 of 70 4. Dr. (Prof.) Ranjan Mallik, Department of Electrical Engineering, IIT Delhi, -- Member 5. Dr. (Prof.) S.N. Sinha, Emeritus Fellow, Deptt. of Electronics & Communication Engg., IIT Roorkee--Member 6. Dr. (Prof.) Girish Kumar, Member of Electrical Engineering Department of the IIT Mumbai --Member 7. Dr. R. S. Sharma, Deputy Director General (SG) Division of RCH, Indian Council of Medical Research (ICMR) --Member 8. Dr. Sarat P. Chandra * AIIMS, New Delhi- Member, (Dr. P. P. Kotwal, AIIMS attended the first meeting on 25-09-2013) 9. Dr. R.C. Murthy, Chief Scientist and Head, Analytical Chemistry from Indian Institute of Toxicology Research Lucknow--Member 10.Shri S. S. Kohli, Director / Sc. 'F', SERC Division from Science & Engineering Research Board (SERB) under the Department of Science & Technology (DST) --Member 11.Shri U. K. Srivastava, Deputy Director General, Telecom Engineering Center (TEC), New Delhi, DoT--Member 12.Shri Nitin Jain, Deputy Director General (CS), New Delhi, DoT--Member 13.Director (CS-III), DOT-- Member Convenor /Shri Rama Shankar Ram Director (CS-TP), DoT– Alternate member convenor * Dr Vivek Tandon from AIIMS attended the meetings as alternate member in place of Dr. Sarat P Chandra. 2. Proceedings of the Committee 2. A. 1st meeting of this Committee was held on 25/9/2013 wherein deliberations were held in accordance with the above said court order and it was decided to study the following documents, which is in line with the directions of Hon’ble High Court.
  • 4. Page 4 of 70 1) Members of the Committee shall study the Report of Prof. (Dr.) Girish Kumar submitted by petitioner as per Hon’ble High Court order dated 10.01.2012 2) Members shall also give their views/ comments on the EMF radiation exposure norms revised by DoT vide license amendment dated 30/12/2011, which are based on the acceptance of recommendations of inter-ministerial committee through office memorandum dated 17/11/2011 on Electro-magnetic Field (EMF) radiation. These revised EMF radiation exposure norms issued on 30/12/2011 came into effect from 01/09/2012. Above documents were made available to all the members of the Committee. Dr. R.C. Murthy from IITR, Lucknow and Prof. (Dr.) Girish Kumar, IIT Mumbai did not attend the first meeting. Prof. (Dr.) Girish Kumar, IIT Mumbai circulated an email to this effect to all the members making certain observations on the constitution of the committee, which were discussed in this meeting. Minutes of meeting are attached in Annexure-I. The committee noted the current status of various guidelines adopted in India with regard to EMF radiation which are as follows: (i) EMF radiation norms for mobile base stations (Cell towers): India adopted the EMF radiation limits recommended by International Commission on Non – Ionizing Radiation Protection (ICNIRP) through the amendment of licenses of the telecom service providers on 04-11-2008. Further, in view of the Office Memorandum dated 17-11-2011, Department of Telecom, vide amendment in the License agreement of the Telecom Service Providers dated 30-12-2011, has adopted stricter norms, following a precautionary approach on EMF exposure limit for the radio frequency Electro-magnetic Field (EMF) by mobile base stations i.e. Base Transceiver Stations (BTSs) which are 1/10th of the limits prescribed by International Commission on Non – Ionizing Radiation Protection (ICNIRP).
  • 5. Page 5 of 70 The revised norms became effective from 01-09-2012. (ii) EMF radiation norms for Mobile Handset - Specific Absorption Rate (SAR): In view of the Office Memorandum dated 17-11-2011, Department of Telecom, has adopted stricter norms for SAR levels of mobile handsets. The new revised SAR limit of 1.6 Watt/Kg, averaged over a mass of 1 gram of human tissue, has replaced the earlier existing limit of 2 Watt/Kg averaged over a mass of 10 gram of human tissue, which was in place since 01-09- 2008. These revised SAR norms for new mobile handsets have become effective from 01-09-2013. 2. B. Discussion on the issues raised in the Petition before the Hon’ble High Court: Subsequent meetings of the committee were held on 21/10/2013, 08/11/2013, 28/11/2013, 16/12/2013 and 30/12/2013. The Committee noted, inter-alia, the following observations of the Hon’ble High Court in its order dated 10-01-2012: “…………. On the other hand, the report of Prof. Girish Kumar filed with the supplementary affidavit seems to raise important questions with regard to safety measures adopted by the Government of India which is precisely narrated as under: 1. The current exposure safety standards are mainly based on the thermal effects, which are inadequate. Non-thermal effects are several times more harmful than thermal effects. According to Dr. Girish Kumar, Microwave radiation is classified as thermal and non-thermal. Out of two, non-thermal effects are more harmful.
  • 6. Page 6 of 70 2. With regard to Microwave Heating Concept, 4.2 KW of microwave power raises temperature of 1 Litre of water by 1 degree C in 1 second. In a microwave oven, temperature of one cup of water increases from 30 degree to 100 degree C in approx. 70 seconds. With 1W power temperature will increase by 1 degree C in 500 seconds. Temperature of ear lobes increases by approx. 1 degree C when cell phone is used for approx. 20 minutes. 3. According to Dr. Girish Kumar, different safety measures have been provided with regard to cell phone as well as SAR in different States of U.S.A. For example, San Francisco Government has made it mandatory for the industry to display SAR value for each set. According to him, people living within 50 to 300 meter radius of the tower are in the high radiation zone and are more prone to ill-effects of electromagnetic radiation. Four cancer cases in three consecutive floors (6th, 7th and 8th) directly facing and at similar height as the mobile phone towers of four telecom companies placed on the roof of opposite building has been found to be true experiment in Worli, Mumbai. With regard to power density, it has been found that it increases for multiple carriers and multiple operators on the same roof top or tower. Dr. Girish Kumar found that the persons residing in vicinity of Cell Tower are prone to suffer with cancer. Overall reading of the report of Dr. Girish Kumar prima facie reveals that the people residing in the vicinity of Cell towers may suffer from different diseases which includes boils, drying up the fluids around eyes, brain, joints, heart, abdomen, etc along with change of electrical activity of brain. Use of mobile phone before bed also disturb the sound sleep. Courts are not experts. Prima facie, the report of Dr. Girish Kumar reveals that the establishment of mobile tower in residential areas of the cities may be harmful. Different anamolies, drawback and Formatted: Font color: Red
  • 7. Page 7 of 70 problems considered by Dr. Girish Kumar in his report, prima facie, do not seem to have been taken into account by the Government of India. …………………….” In consideration of the observations and directions of Hon’ble High court, members of the committee took note of the fact that the petitioner has relied on the report of Prof. (Dr.) Girish Kumar. As Prof. (Dr.) Girish Kumar is also a member of this Committee, he was requested to make a presentation and express his views on the subject matter considering the matter in the petition and observations & directions of Hon’ble High Court. Prof. (Dr.) Girish Kumar made a presentation to the Committee on his views on the issues raised in the said petition. Keeping in view the directions of the Hon’ble High Court, detailed discussions took place on these issues. Prof (Dr.) Girish Kumar’s presentation included all the issues that the petitioner had submitted before Hon’ble High Court. The gist of discussion is as placed below in the Table-1: Table-1 Sl . Main issues brought out in the petition – presented by Prof. (Dr.) Girish Kumar Details of deliberations held by the Committee 1 People living within 50-300 meter radius are more prone to dangerous ill effects of EMR on human health. There are some evidence to this effect. It was explained to the Committee members by him that if present ICNIRP guidelines are followed then human body would absorb microwave energy of 583.2 kw-sec which would amount to keeping human body in microwave oven for 19 minutes/day. Thermal effects of EMF radiations are explained in this example as there is a comparison with microwave heating. It has been assumed by Prof. (Dr.) Girish Kumar that human body is a cylinder of fluid and has no thermal regulation of its own. Further, to understand the effect of EMF radiation of human body, following factors need to be considered: a) According the scientific data
  • 8. Page 8 of 70 Further, with regard to Microwave Heating Concept, 4.2 KW of microwave power raises temperature of 1 Litre of water by 1 degree C in 1 second. In a microwave oven, temperature of one cup of water increases from 30 degree to 100 degree C in approx. 70 seconds with 500 watt of microwave power. With 1W power temperature will increase by 1 degree C in 500 seconds. The temperature rise can be calculated using microwave heating equation, which is the basis of microwave heating. Increase in the temperature is linearly proportional to the power and time. Temperature of ear lobes increases by approx. 1 degree C when cell phone is used for approx. 20 minutes published in reputed scientific journals, the Absorption cross- section (ACS), which is defined as the ratio of power absorbed to incident power density, of human body to EMF radiation is between 0.2 to 0.3 within mobile frequency bands as it is frequency dependent. In the same paper, values mentioned are 0.4 to 0.5 at 1GHz but the members chose to write lower value, which is around 2 to 3 GHz. These values have been determined by considering that the human body is totally immersed in a uniform EMF. Such a situation can only be created in an isolated environment like laboratory. For an actual directional exposure, the value of ACS will be even less. After this issue was raised in the committee, I did the measurement in the antenna lab at IIT Bombay, the reflected wave was less than 5%. This fact was presented to the committee but they chose
  • 9. Page 9 of 70 to ignore for the reason best known to them. b) Human body is not homogeneous. It consists of several layers like skin, tissue, fat, muscle etc and different layers of body have different dielectric constants. c) Only about 20%-30% of the human body shall be actually exposed to the directional beam of EMF radiation from the BTS antenna. In his computations, Prof (Dr.) Girish Kumar has assumed that the full EMF radiated power (at peak traffic value) is falling on the human body from all sides i.e. from every angle in 360o and also from top and bottom as if live human being is kept in a reverberation chamber having EMF radiation from all sides at peak values. He further assumes that the entire electro-magnetic (E.M.) power in the incident wave enters into the human body which is not correct. the reflected wave is less than 5%. d) BTS generally radiates at
  • 10. Page 10 of 70 much lower power than peak power. (there are many transmitting tower antennas on the same roof top, so total power transmitted from multiple antennas can be greater than peak power of a single transmitting antenna). e) World Health Organisation (WHO) in its fact sheet No. 193 of 2011 has mentioned that at the frequencies used by mobile phones, most of the energy is absorbed by the skin and other superficial tissues, this is not correct, there is depth of penetration of several centimeters at 900 and 1800 MHz resulting in negligible temperature rise in the brain or any other organ of the body. WHO fact sheet No. 193 of 2011 also mentions about cell phone as possibly carcinogen (Class 2B) Prof. (Dr.) Girish Kumar has agreed that all these factors have not been considered in the calculations given by him. I did not agree with the committee but they chose to write for
  • 11. Page 11 of 70 the reason best known to them.Further, Prof. Girish Kumar has also not taken into account a very important factor i.e. the self thermo- regulatory mechanism of the human body. As far as thermal effects are concerned, committee also noted that power density of the Sun’s radiation is of the order of about 1000 Watt/m2 which is more than 1000 times higher than EMF radiation power from BTSs. However, due to the thermo- regulatory mechanism of human body, temperature of human body remains regulated even if exposed to very high thermal radiation from Sun. Sun exposure is not continuous whereas microwave radiation is 24x7 due to cell tower radiation. Sun heating is from outside to inside. The skin of human body acts as an insulator from sun and as the temperature increases, skin will either feel the burning sensation or it starts sweating. also, clothes act as an insulator. In addition, air breeze takes away the heat. Also, people who take sun bathing, have reported skin cancer. Whereas, microwave heating is from inside to outside. It penetrates the skin and heats up the blood, fluid, fat, etc. This heat is trapped inside the human body with no escape through the skin. Hence, the committee observed that the conclusion in Prof. (Dr.) Girish
  • 12. Page 12 of 70 Kumar’s report that ICNIRP guidelines would result into absorption of microwave energy of 583.2 kw-sec in human body and would amount to keeping human body in microwave oven for 19 minutes/day is incorrect, highly misplaced and misleading. (ICNIRP guideline is only for short term exposure and not for 24x7. Also, there are multiple transmitting antennas. In addition, for GSM1800, ICNIRP mentions safe level of 9.2 Watts/square meter, which is worse). Further, at distances in the range of 50-300 meters, the power density of the signal from BTS becomes very low as compared to the prescribed precautionary maximum limits of EMF radiation in India. Only a fraction of power radiated from BTS reaches a particular spot in the EMF lobe of power radiation pattern, where a human being may be present. Further, considerable attenuation of the E.M. wave occurs as it passes through the concrete walls and roof of the buildings. Committee also noted that radiation levels below and near to antenna are very low due to height and tilt of the antenna considering the
  • 13. Page 13 of 70 antenna radiation pattern. Actual measured EMF radiation at any place vis-à-vis the radiation limit as recommended by DoT is the criteria to take the precautionary measures. We have been repeatedly telling that India's precautionary limit of 450 miilwatts/square meter for GSM900 is very high for 24x7 exposure, it should be less than 0.1 miilwatts/square meter for 24x7 exposure. In view of above discussion, the committee notes that irrespective of the distance, so long as the EMF radiation power levels, in the vicinity of Base Stations, are below the prescribed limits, limit must be reduced to less than 1 miilwatts/m2 there cannot be any cause of adverse thermal what about non-thermal effect? health effects on human beings due to base station radiation. So far as non-thermal effects of EM radiation are concerned, a lot of research is going around the world but currently there is no CONCLUSIVE scientific evidence which establishes that EMF has harmful non-thermal effects. BIO- INITIATIVE report 2012 has given Formatted: Superscript
  • 14. Page 14 of 70 references of 3800 scientific research papers but committee chose to ignore all the time due to reasons best known to them However, some countries are taking a precautionary approach by reducing EMF levels below those specified by ICNIRP and India is one of them which has reduced the prescribed EMF radiation levels by a factor of 10. (many countries have chosen 1/100 to 1/1000th level of ICNIRP. They care for the health of their citizen. We have to also take care of health of people in India). Thus, the committee concludes that the assertion by Prof. (Dr.) Girish Kumar that people living within 50-300 meter radius of mobile tower are more prone to dangerous ill effects of EMF radiation, are not backed by conclusive scientific evidences. (I also mentioned to the committee that people living in the range of 10 to 50 meter are even more prone to health hazards as many towers are installed within this There are many epidemiological studies, which have reported health
  • 15. Page 15 of 70 hazards to the people living within 300m, such as, sleep disorder, headaches, irritation, cardiovascular problems, cancer, etc. but committee chose to ignore it.) Regarding Radiation from Mobile Hand Set: As far as rise of temperature of ear lobes by approx. 1 degree Celsius is concerned on using cell phone for approx. 20 minutes, Committee is of the view that heat energy is generated due to the working of electronic components in the mobile phone as well as EMF radiation from mobile phone falling on the ear lobe. Committee further noted the fact that the thermo-regulatory mechanism of human body takes care of the localized heating, thus the temperature rise of ear lobe is limited to less than 1˚C by use of mobile handsets very close to the ear lobe even for continuous use for longer durations also. The claimed biological effects of EMF radiations are discussed in detail in item No. 4 of this table (TABLE-1). Committee referred to the paper,
  • 16. Page 16 of 70 "Calculation of change in brain temperatures due to exposure to a mobile phone" by G M J Van Leeuwen et al, published in 1999. They presented only theoretical results whereas measured results show much higher temperature rise. Committee chose to selectively write lower value. However, so far, no conclusive evidence on adverse health effects by EMF radiation from mobile handset has been found internationally by World Health Organization (WHO). As per the available evidences, such changes are described as reversible and further studies are underway in different forums to establish any linkage, if any, of adverse health effects with EMF radiation from mobile handsets. (No conclusive evidence does not mean no evidence. WHO accepted cell phone as possibly Carcinogen in 2011, where as earlier they had not classified as Class 2B. The reason is that radiation hazards are cumulative in nature and as usage is increasing with time, larger number of people are reporting health hazards. Conclusion: In view of the discussion as above, committee concludes that these
  • 17. Page 17 of 70 findings of Prof. (Dr.) Girish Kumar of comparing heating of water in microwave oven with human health effects of EMF radiation from mobile tower are incorrect. (people do cook non-veg food in the microwave oven, which is based on heating principle of water molecules present in the food items) Self thermo regulation of human body is an important aspect which has been totally ignored in this example. (Self thermo regulation is effective for short duration but if the source is continuous, then it fails. Human body has fighting mechanism, which is not effective forever especially for children, pregnant women, older people, patients, etc.) Further, as regard the temperature rise of ear lobe and dangerous ill effects caused by it due to radiation from mobile phones/handset are not conclusively supported by proven scientific studies. Committee referred to the paper, "Calculation of change in brain temperatures due to exposure
  • 18. Page 18 of 70 to a mobile phone" by G M J Van Leeuwen et al, published in 1999. They presented only theoretical results whereas measured results show much higher temperature rise. Committee chose to selectively write lower value. Therefore such comparisons are highly misleading and may create unfounded fear and panic in the minds of people, which is totally unwarranted and should be avoided. Creating awareness to the people is extremely important. Cell operators and their associates are giving false assurance to the people that there are no health hazards. Why are they ignoring 1000's of scientific papers showing adverse effects. 2 If one stands 1 meter away from cell tower antenna, body temperature would rise to 2˚F in 1 hour and by 8˚F in 4 hours. Increase in the temperature is linearly proportional to the power and time. The equation is given in Point 1. Self thermo regulation is effective for short duration but if the source is continuous, then it fails. Human body has fighting mechanism, which is not effective forever especially for children, pregnant women, older This assertion of Prof. (Dr.) Girish Kumar is related to thermal effects of EMF radiation on human body. In continuation of deliberations of the committee on earlier item regarding thermal effects, committee notes the following: The assumptions used by Prof. (Dr.) Girish Kumar are hypothetical. Such assumption of a person being close to and in front of very narrow beam of antenna at that height in the air is rhetorical and impractical.This
  • 19. Page 19 of 70 people, patients, etc. example was given to prove cell operators and their associates that non-ionizing radiation can cause damage. Further, there is no scientific evidence available so far to prove that the temperature of the human body steadily rises by 2˚F in one hour and 8˚F in 4 hours and so on inspite of self thermo regulation. This calculation is based on microwave heating equation, which is the basis of microwave heating. Also, self thermo regulation is effective for short duration but if the source is continuous, then it fails. Human body has fighting mechanism, which is not effective forever. The rise in body temperature due to EMF exposure depends upon whole- body SAR for which the FCC limit for general public is 0.08 W/Kg. There are ample number of published scientific studies which show that at these SAR levels, the rise in body temperature is of the order of 0.1 degree centigrade (0.18˚F) for long exposure times. (For cell tower radiation, limit is generally defined in watts/m2 .) Formatted: Superscript
  • 20. Page 20 of 70 The thermal time constant and thermo-regulatory mechanism of human body have been totally ignored by Prof. (Dr.) Girish Kumar. self thermo regulation is effective for short duration but if the source is continuous, then it fails. Human body has fighting mechanism, which is not effective forever especially for children, pregnant women, older people, patients, etc.Thus, the calculation given by him has no scientific basis as far as human body or living organisms are concerned in real situations. The factors affecting the EMF exposure to human body as deliberated in point 1 above also apply in this case. The sole criteria of safety is that with present level of power radiated from antenna, the radiation level at the location around the tower where the people could be present should be within the limits as prescribed by the DOT which are already 1/10th of ICNIRP norms. DOT limit of 1/10th of ICNIRP norms is very high for 24x7 exposure, it should be less than 0.1 milliwatts/m2
  • 21. Page 21 of 70 Conclusion: The committee has come to the conclusion that Prof. (Dr.) Girish Kumar has made an over simplification of the complex phenomenon of human response to such stimuli. Such unfounded and hypothetical analysis is ill conceived. This is complete misrepresentation of actual position and shall create only confusion, misperception and unfounded fear in the minds of general public, which should be avoided. (Creating awareness to the people about possible health hazards is important. Human body is complex that is why some simplifications have been made to explain to general public. Cell operators and their associates take advantage of this complex problem to mislead people that health hazards are not conclusively proven (not conclusive does not mean no proof) 3 Prof. (Dr.) Girish Kumar while quoting a newsletter published by him (Sept-Oct, 2013) has referred to Federal Communications Commission (FCC) Committee makes the following observations: a. FCC limits for occupational exposure to EMF radiation for
  • 22. Page 22 of 70 guidelines of USA. According to his interpretation about the FCC guidelines, power density limits from cell tower should beis f/300 mw/cm2 for 6 minutes use and f/1500 mw/cm2 for 30 minutes use. As per his interpretation, for 24 hour exposure (which is the case, as the cell tower radiates continuously) FCC guidelines recommend exposure limit of 12.5 mw/m2 . With regard to mobile handset, India has adopted SAR value 1.6 w/kg averaged over 1 gm of tissue which is same as FCC guidelines. Prof. (Dr.) Girish Kumar argued and interpreted that use of mobile phone only upto 6 minutes is recommended by FCC but he has found use of phone safe upto 10 to 30 minutes. I had also mentioned that there is a safety margin of 3 to 4 in the guideline. Also, 10 to 30 minutes is safe depending upon SAR value of phone 300-1500 MHz frequency are f/300 mwatt/cm2 with average measurement exposure time of 6 minutes. Whereas for general population, EMF radiation exposure for 300- 1500 MHz frequency, the FCC limits are f/1500 mwatt/cm2 with average measurement exposure time of 30 minutes. These two limits are for different environments and hence can not be compared. b. While the FCC standard for radiation is f/1500 mwatt/cm2 , when expressed in the unit of watts/m2 , this limit becomes f/150 watts/m2 . This is far relaxed than the limit of ICNIRP which is f/200 watt/m2 . The FCC limits are followed in USA, Canada, and Japan besides few more countries. India has adopted 1/10th of ICNIRP norms which is more stringent and is f/2000 watt/m2 . c. While, measuring this parameterit is not written anywhere measuring, everywhere it is written exposure, the average of 30 minutes of radiation is taken so as to avoid any misreading due to instantaneous increase. The contention of Prof Girish Kumar that the same limit, when averaged over 6 minutes, becomes f/300 mw/cm2 is total Formatted: Font color: Red
  • 23. Page 23 of 70 misunderstanding of the standard. d. Cell towers are designed to radiate continuously for providing reliable and continuous mobile phone service. Committee observed that this interpretation of Prof. (Dr.) Girish Kumar, of reducing the radiated EMF power from cell tower depending on period of use, is baseless and hypothetical. e. Committee members explained that duration of thirty minutes mentioned in FCC guidelines is the duration of any sample over which the measurement exposure should be done and average of the values gathered during these thirty minutes should be taken as the value of EMF radiation power density observed. Committee noted that the FCC guidelines are available in public domain with the above explanation. These guidelines (FCC No. OET 56) have also been shared among all the members of the Committee. (ANNEXURE-II) Further, averaging is used in any measurement to avoid judgement on any instantaneous observation. This is a very well internationally established scientific procedure of
  • 24. Page 24 of 70 measurement. f. Committee further noted that in case of ICNIRP guideline, power density is to be averaged over any 6 minutes period for the purpose of measurement no where it is written measurement, everywhere it is written exposure of EMF radiation. ICNIRP guidelines mentions that “For frequencies between 100 KHz & 10 GHz, Seq (i,e, power density) are to be averaged over any 6 minute period.” This no where it is written measurement, everywhere it is written exposuremeasurement standard however does not mean that the radiation exposure to the public has to be limited to only six minute, as being made out in the meeting by Prof (Dr.) Girish Kumar. g. It was opined by the committee that as long as the absolute prescribed limit of EMF radiation power level is not exceeded, duration of exposure is not significant taking into account the self thermal regulatory mechanism of the human body. Rather, absolute prescribed limit of EMF radiation power level are recommended by the international bodies keeping in
  • 25. Page 25 of 70 view the continuous radiation from cell towers. Duration of exposure is extremely important. If food is cooked in the microwave oven (even at a lowest power level) for 10 minutes or 100 minutes, there will be huge effect. Self thermo regulation is effective for short duration but if the source is continuous, then it fails. h. The limit of 6 minutes radiation at the recommended power levels of EMF radiation by FCC as deduced by Prof. Girish Kumar is absolutely incorrect and gross misrepresentation of the FCC recommendation. Similarly, the limits deduced by him for 24 hours use is also utter misrepresentation of the FCC standard. (FCC has clearly mentioned reduced guidelines for 30 minutes compared to 6 minutes. I had clearly mentioned to the committee that 24 hours is an extrapolation but they chose to ignore. i. In the context of 30 minutes average exposure, FCC in their document No. OET Bulletin 56 has clarified that “For such public exposure situations, the MPE (Maximum Permissible Exposure) limits normally apply for continuous exposure. In other words, as
  • 26. Page 26 of 70 long as the absolute limits are not exceeded, indefinite exposure is allowed.” Duration of exposure is extremely important. If food is cooked in the microwave oven (even at a lowest power level) for 10 minutes or 100 minutes, there will be huge difference. Same is true for a person standing in the sun for 10 or 100 minutes. j. Same applies to the measurement of SAR values for average 6 minutes and has no relation to the duration of use of mobile phone by the people. Interphone study has clearly mentioned that people who use cell phone for longer duration (30 minutes or more) are more prone to health hazards than who use for less than 6 minutes. Conclusion: Committee after carefully deliberating all the aspects concludes that the interpretations and projections given by Prof (Dr.) Girish Kumar are absolutely incorrect and are complete misrepresentation of the facts. It is other way around, committee chose to mis-represent the interpretations and projections given by me for the reasons best
  • 27. Page 27 of 70 known to them. 4 Prof. Girish Kumar explained that the EMF radiation causes biological effects such as cancer, brain tumor, localized heating, drying up of fluids around eyes, brain, joints, heart, abdomen etc, sleep disruption headache, Fatigue, Dizziness etc. He also explained the effect of EMF radiation on environment particularly on Birds and bees also. The non-thermal effects due to EMF radiation on human body are also termed as Biological effects. Committee noted that the international studies have taken into account the non-thermal (biological) effects of EMF radiation on human body. The international standards have also taken in to account the biological effects before prescribing the standards. 1. WHO in its Facts sheet no. 304 of May 2006 has stated that “International exposure guidelines have been developed to provide protection against established effects from RF fields by International Commission on Non-Ionizing Radiation Protection (ICNIRP,1998) and the Institute of Electrical and Electronics Engineers(IEEE,2005). National authorities should adopt international standards to protect their citizens against adverse levels of RF fields.
  • 28. Page 28 of 70 They should restrict access to areas where exposure limits may be exceeded.” All the above are outdated. In 2011, WHO reported cell phone as possibly carcinogen (Class 2B). What is the point in mentioning earlier reports? Also, there are growing evidences of health hazards in the last few years (as cell phone/tower radiation is cumulative in nature). There are 1000's of scientific papers reporting health hazards but committee chose to ignore. 2. After going through the ICNIRP report, committee finds that biological studies related to EMF exposure have been extensively covered in the report of ICNIRP on page no 505 under the heading “Biological Basis for Limiting Exposure (100khz- 300Ghz)”. It is noted by the committee that ICNIRP report, inter- alia, takes into account (i) Epidemiological studies (ii) Reproductive outcome (iii) Cancer studies (iv) laboratory studies (v) Volunteer studies ( vi) Cellular and
  • 29. Page 29 of 70 animal studies (vii) Special conditions for pulsed and amplitude modulated waveform. Both direct and indirect effects of EMF have also been taken into account for conducting biological studies. 3. Committee noted that all these facts are already documented in the ICNIRP report. After consideration of the study of biological effects of EMF radiation only, ICNIRP has come out with detailed guidelines for recommending the EMF exposure limits. (ICNIRP is an NGO, whose funding has been questioned by large number of people. Google search words as "ICNIRP funding" leads to several websites: The following websites mentions about Weaknesses in ICNIRP’s rationale for its 1998 guidelines and Uncertainties over ICNIRP’s membership and aims: http://wiredchild.org/component/content/article/46 -hidden/99-icnirp.html The following paragraph is taken from the above site: "It should be noted that ICNIRP is not a transparent organization. It has never disclosed the sources of its funding nor the procedures for the selection of its members. ICNIRP was established by Mike Repacholi, who has long had financial ties to both the telecom and electric utility industries. “ The above has been reported in my newsletter, which was presented to committee. Further, according to online reply to a
  • 30. Page 30 of 70 question by WHO dated 20th Sept 2013, WHO has recognised that “to date studies provide no indication that environment exposure to RF fields, such as from base station, increase the risk of cancer or any other disease.” Moreover with regards to other Health Effects this release mentions that: “Scientists have reported other health effect of using mobile phones including changes in brain activities, reaction times, and sleep patterns. These effects are minor and have no apparent health significance. More studies are underway to try to confirm these findings.” Only second part of the WHO reply is included. First part mentions that exposure to the radiofrequency (RF) fields emitted by mobile phones is generally more than a 1000 times higher than from base stations and there is greater likelihood of any adverse effect being due to handsets. THIS IS VERY IMPORTANT, it implies that base station radiation is 1/1000 of mobile phones. We have measured radiation density of many mobile phones, when they are in the
  • 31. Page 31 of 70 talk mode, and it is around 100 mW/m2 , so 1/1000th will be 0.1mW/m2 . Thus, the safe radiation norm should be around 0.1mW/m2 and not 450mW/m2 . Other international studies have also studied biological effects due to EMF radiation and found that Biological effects corresponding to generally reversible changes in the inner functioning of the body are observed, as is also found in the case of exposure to different stimuli of everyday life. However, there are no conclusive evidence (no conclusive evidence does not mean no evidence) to establish any causal link between the effect of EMF radiation with biological effects described in cell models, animals or humans, and any possible resulting health effects. It is highly relevant to mention that the Committee took note that while summarizing the Health effect of EMF radiation, WHO has mentioned the following: “…..Heating is the main biological effect of the electromagnetic fields of radiofrequency fields. In microwave ovens this fact is employed to warm up food. The levels of radiofrequency Formatted: Superscript Formatted: Superscript
  • 32. Page 32 of 70 fields to which people are normally exposed are very much lower than those needed to produce significant heating. The heating effect of radio waves forms the underlying basis for current guidelines. Scientists are also investigating the possibility that effects below the threshold level for body heating occur as a result of long-term exposure. To date, no adverse health effects from low level, long-term exposure to radiofrequency or power frequency fields have been confirmed, but scientists are actively continuing to research this area. Biological effects or health effects? What is a health hazard? Biological effects are measurable responses to a stimulus or to a change in the environment. These changes are not necessarily harmful to your health. For example, listening to music, reading a book, eating an apple or playing tennis will produce a range of biological effects. Nevertheless, none of these activities is expected to cause health effects. The body has sophisticated mechanisms to adjust to the many and varied influences we encounter in our environment. Ongoing change forms a normal part of our lives. But, of course, the body does not possess adequate compensation mechanisms for all biological effects. Changes that are irreversible and stress the system for long periods of time may constitute a health hazard. An adverse health effect causes detectable impairment of the health of the exposed individual or of his or her offspring; a biological effect, on the other hand, may or may not result in an adverse health effect.
  • 33. Page 33 of 70 It is not disputed that electromagnetic fields above certain levels can trigger biological effects. Experiments with healthy volunteers indicate that short- term exposure at the levels present in the environment or in the home do not cause any apparent detrimental effects. Exposures to higher levels that might be harmful are restricted by national and international guidelines. The current debate is centred on whether long-term low level exposure can evoke biological responses and influence people's well-being. …………………. Conclusions from scientific research In the area of biological effects and medical applications of non-ionizing radiation approximately 25,000 articles have been published over the past 30 years. Despite the feeling of some people that more research needs to be done, scientific knowledge in this area is now more extensive than for most chemicals. Based on a recent in-depth review of the scientific literature, the WHO concluded that current evidence does not confirm the existence of any health consequences from exposure to low level electromagnetic fields. However, some gaps in knowledge about biological effects exist and need further research. ………………..” (Source: WHO website: http://www.who.int/peh- emf/about/WhatisEMF/en/index1.html Copy attached as Annexure-III) (This is an Extract from Electromagnetic
  • 34. Page 34 of 70 fields published by the WHO Regional Office for Europe in 1999. This report is an outdated report and should be discarded after WHO reported cell phone as possibly carcinogen (Class 2B) in 2011. I do not know why committee members chose to report outdated report. They should be concerned about health of the public. Committee has noted that the claims made by Prof. (Dr.) Girish Kumar on health effects of EMF radiation are not supported by any scientific evidence Prof. (Dr.) Girish Kumar appears to have heavily relied only on Bio-Initiative Report 2007 & 2012. This report is one of the extreme view among thousands of studies on the subject and does not provide any conclusive evidence. Committee noted that WHO, after studying approximately 25,000 studies over past 30 years has concluded that current evidence does not confirm the existence of any health consequences from exposure to EMF radiation. WHO has concluded that considering the very low exposure levels and research, there is no convincing scientific evidence that the prescribed EMF exposure from base station
  • 35. Page 35 of 70 cause adverse health effects. As regards the health effect of radiation from prolonged use of mobile phone, International Agency for Research on Cancer (IARC), an agency of WHO, has classified radiofrequency electromagnetic fields as possibly carcinogenic to humans (Group 2B), a category used when a causal association is considered credible but when chance, bias or confounding cannot be ruled out with reasonable confidence. WHO has further stated that a large number of studies have been performed over the last two decades to assess whether mobile phones pose a potential health risk. To date, no adverse health effects have been established as being caused by mobile phone use. Committee also noted that in fact substances, mixtures and exposure circumstances classified by the International Agency for Research on Cancer (IARC) as ‘Group 2B’, inter- alia, include coffee, Aloe vera (whole leaf extract), Pickled vegetables (traditional in Asia), Talc-based body
  • 36. Page 36 of 70 powder etc. (source IARC Monographs) However, more studies are underway at various forums (National as well as International) to find any conclusive evidence to the harmful health effect from EMF radiation from cell towers and mobile phones. Conclusion: The Committee is of the opinion that the limits adopted by India for EMF radiation from cell tower as well as from mobile phones account for all the biological effects of radiation, as these limits are much lower than internationally adopted ICNIRP recommendations which take in to consideration thermal as well non-thermal effects of radiation.iCNIRP does not account for non-thermal effects More studies are underway particularly relating to prolonged use of Mobile phones. Hence at this stage, there is no cause of alarm with regard to the possible dangerous ill effects on human health as mentioned by Prof. (Dr.)
  • 37. Page 37 of 70 Girish Kumar. However, national authorities must keep a watch on the studies and research work being carried out in this area for finding conclusive evidence, if any. 5 The author presented a case study of Usha Kiran Building, Worli, Mumbai wherein six cases of cancer were reported. This building was facing the Antennas placed by four telecom companies on the opposite side of another building. Further, while giving example of various countries, he has brought out during discussions that in Mumbai at Riddi Park, Thakurlee, within 4 months of occupying the top floor flat, Mrs. Bhat was diagnosed with brain tumour and her neighbour delivered a baby with cancer of spinal cord i.e. within a duration of 9 months of pregnancy. This has also been brought out by him in his report submitted to Secretary, DOT in December 2010. (this part has been reported in Mobile Tower Grievance Forum, http://mtgf.blogspot.in/ The Committee’s response against point 4 above details the biological studies which have not been taken into consideration by ICNIRP while recommending the exposure limits of EMF radiation. ICNIRP has clearly mentioned only thermal effects It is amply clear from the studies of ICNIRP/WHO that there is no established relationship between radiation from mobile towers and cancer/tumour. These case studies of Usha Kiran building and Riddi Park quoted by Prof. Girish Kumar highlights EMF radiation as the only environmental factors while ignoring all other factors which might be significant. Committee opined that, without any conclusive evidence, such examples could be a matter of further analysis rather than saying that EMF radiation was an environmental factor in these case studies for causing cancer/tumour.
  • 38. Page 38 of 70 Committee felt that such selective highlighting of EMF radiation, as the only environmental factor, may cause unfounded fear and scare among public and should be avoided in the absence of any conclusive evidence. Members have further questioned the assumption of Prof. (Dr.) Girish Kumar that cancer can develop during a short period of exposure to EMF radiation to a new born baby during pregnancy in 9 months time whereas as per the present findings, latency period for developing cancer in human being is 10-15 years. Similarly assumptions of Prof. (Dr.) Girish Kumar that brain tumor has developed during 4 months of exposure to EMF radiation is also not acceptable as the latency period is much higher. Conclusion: It is noted by the Committee that measured EMF radiation power levels from cell tower have not been quoted by Prof. (Dr.) Girish Kumar in this example while ignoring all other factors which might be relevant. Also no peer reviewed conclusive analysis has
  • 39. Page 39 of 70 been presented by him. This makes the case study highly misleading and objectionable and at best be termed as anecdotal. Several epidemiological studies have been reported in Paris, Spain, Netherlands, Germany, Brazil, Austria, Israel, Egypt, Swedish, India, etc. (this was mentioned by one of the members, file is attached - List os studies of adverse afects of RFR). In my first newsletter, given to all committee members, I had given several cases of cancer clusters in various cities of India. However, committee report did not include it for the reasons best known to the members. 6 International Exposure Standards for some of the countries (about 12 only) was presented that the radiation norms vary from 2w/m2 to as low as 0.00001w/m2 The examples taken by Prof. (Dr.) Girish Kumar are from very few countries and some are the examples of small local bodies/counties in a country. China and Russia have adopted 0.1W/m2 (=100 m1W/m2 ) and these are not small countries. These are isolated examples and as per information available, these Formatted: Superscript
  • 40. Page 40 of 70 norms are not even legally binding in some of these countries. It is worthwhile to mention that most of the countries in the world have adopted ICNIRP limits as recommended by WHO. Moreover, India is among the very few countries who have adopted precautionary approach and have adopted much lower norms than rest of the world which is 1/10th of ICNIRP recommended EMF radiation limit. India has adopted 1/10th of ICNIRP limits as an abundant precaution. Switzerland has adopted 0.04W/m2 . Austria (Salzburg) has adopted 0.001W/m2 . Bio-Initiative proposed 0.0001 W/m2 but committee chose to ignore these. Conclusion: India’s prescribed limits for radiation are already much lower than most of the countries in the world. Therefore, there is no need to further reduce the limits without conclusive studies by International standards bodies and India’s own conclusive research and findings. There is an urgent need to reduce
  • 41. Page 41 of 70 the limit from health point of view. Bio-Initiative proposed 0.0001 W/m2 but committee chose to ignore these. 7 Analysis of certain studies done in few countries have been quoted by Prof. (Dr.) Girish Kumar. These include Spain, Israel, Germany, Sweden, Brazil and India It is noted by the committee that only few select studies, many of them possibly without any peer review, have been picked in the example given in the presentation by Prof (Dr.) Girish Kumar, simply to buttress his own point of view. Whereas International Organisations like United Nation’s WHO conduct peer review of the independent studies done by an individual or a country and have taken into account approximately 25,000 studies over past 30 years from all over the world. Several epidemiological studies have been reported in Paris, Spain, Netherlands, Germany, Brazil, Austria, Israel, Egypt, Swedish, India, etc. In my first newsletter, given to all committee members, I had given several cases of cancer clusters in various cities of India. Conclusion: The studies quoted by Prof. (Dr)
  • 42. Page 42 of 70 Girish Kumar, therefore, may be relevant for conducting further peer review at international level for appropriate correlation and can not be relied upon at this stage without any conclusive evidence. The Bio-Initiative Report 2012 is prepared by 29 scientists and health experts from 10 countries and was uploaded in Jan. 2013 to create awareness. It is an update of Bio-Initiative Report 2007, which was published by Bio-Initiative Working Group that looked at more than 2,000 peer reviewed studies documenting bio-effects and adverse health effects from EMF exposures. They recommended safe radiation density of 1 milliwatts/m 2 for outdoor and 0.1 milliwatts/m 2 for indoor continuous exposure. Bio-Initiative 2012 assessed 1800 new research papers (from 2006 to 2011) and mentioned that Bio-effects are clearly established and occur at very low levels of exposure to electromagnetic fields and radiofrequency radiation. Even at 0.03 milliwatts/m 2 , researchers have reported headaches, concentration difficulties and behavioral problems in children and adolescents; and sleep disturbances, headaches and concentration problems in adults. 8 Comparison of Automobile industry with Mobile industry was explained to the members by comparing air pollution with radiation. Comparison of cigarette with cell phones was also explained Committee deliberated on the issue and noted that studies are available to link outdoor air pollution with human health. IARC, an agency of WHO, in its press release dated 17th October 2013 has already classified the ‘Outdoor air pollution’ as carcinogenic to humans as ‘Group 1’ which is the highest category. Hence,
  • 43. Page 43 of 70 it is highly inappropriate to compare outdoor air pollution with EMF radiation as no conclusive evidence has emerged so far regarding ill effects from EMF radiation on human health. Similarly, ill effects of cigarette smoking can not be compared with mobile phone use. There is no conclusive evidence about the ill effects of mobile phone use at the most stringent SAR levels as adopted in India. (No conclusive evidence does not mean any evidence. Committee deliberately tried to play with words). To reiterate, Committee noted that India has already adopted a more precautionary approach in fixing the present norms as mentioned below: (i) For Cell Towers: 1/10th of ICNIRP limit as the prescribed limit of EMF radiation from cell tower. This limit is very high for 24x7 exposure. It should be
  • 44. Page 44 of 70 less than 0.1 mW/m2 . (ii) For Mobile Phones: SAR values adopted in India are 1.6Watt/Kg averaged over 1gm tissue, which are most stringent. The limit of 1.6W/Kg is good for 6 minutes with a safety margin of 3 to 4. So, people should not use cell phone for more than 10 to 30 minutes depending upon the SAR value. Conclusion: The Committee observed that it is incorrect to correlate automobile industry or smoking with EMF radiation. Such type of comparison of incomparable situation creates misconception and unfounded anxiety among the people. People understand automobile pollution and smoking hazards, so to correlate, this example was given. Also, worst automobile pollution is felt when a person is on crowded road and smoking effect is felt when person smokes. However, cell tower Formatted: Superscript
  • 45. Page 45 of 70 radiation is 24x7, which is absorbed by every human being, birds, animals, trees, plants, etc. 2. B. 1. During discussions, Prof. Girish Kumar also referred to the report of 24 faculty members of various IITs which was issued by Prof. Ashok Jhunjhunwala of IIT Madras in September 2013. Prof. Ashok Jhunjhunwala is a board member of one of telecom companies, Prof. Girish has informed the committee members that he personally does not agree with this report. As Prof. Girish Kumar referred to the report issued by Prof. Ashok Jhunjhunwala of IIT Madras, a member of this committee Dr. Prof. S. N. Sinha circulated photocopy of a statement issued in September 2013, by Prof. Ashok Jhunjhunwala IIT Madras, on behalf of 24 faculty members of various IITs on effects of EMF radiation on health. (Annexure-IV) Committee noted that this report included Prof. Abhay Karandikar (presently HOD, Electrical Engineering Deptt. IIT Bombay) and two other faculty members from IIT Bombay (from the same Electrical Engineering Department of IIT Bombay to which Prof (Dr.) Girish Kumar belongs). (Three faculty members mentioned here have not worked on microwaves, antennas, microwave heating principle, biological effects, etc.) Gist of their recommendations is as follows: “1) We consider the recommendations of DoT, Government of India, to be sensible and based on the international best practices at this point in time. They should be implemented strictly, including ensuring radiation norms are met at windows, balconies and roof-tops near cell-towers. At this stage, there is no further knowledge available that warrants a change in the recommendations. Results of new research, as well as complaints from citizens, should be carefully
  • 46. Page 46 of 70 examined on a continuous basis, and the recommendations modified as found appropriate. However, caution should be exercised to avoid ad-hoc decisions regarding restrictions on tower locations as long as they meet the stringent guidelines, and to avoid unnecessary panic and fear among the citizens. 2) We further would like to see the following: i) Creation of a public database, where all study reports (pro and con) on the health implication of EM radiation should be placed. Also, all arguments in favour and against putting higher restrictions on radiation should be placed. The site should become a public repository for all information, so that it can be analyzed on a continuous basis. This should be supervised by a committee of academicians. II) As the bit-rates required on Internet increases and usage of Internet in India increases, there will be more and more usage of wireless (especially in the absence of adequate wired infrastructure in India). Further higher bit-rates imply higher RF energy transmitted if energy per bit remains the same. India needs to evolve a focused scientific program to develop technological solutions to reduce transmitted energy per bit required by a factor of ten in the next five years and by a factor of hundred in the next ten years. Difficult though these goals may appear today, focused scientific research should get us there. III) There is a need to conduct on a continuous basis multiple scientific studies on the subject of short-term, mid-term and long-term health implications of EM radiations. The studies should be reviewed and thereafter published. DST, DBT, ICMR etc may fund such studies. Disclosure: All of us have been working on R&D in telecom for 5-35 years. From time to time, some of our work has been funded by
  • 47. Page 47 of 70 various Govt. agencies and by telecom operators (mostly through telecom centre of Excellence at IITs). Some of us have been consultants to telecom manufacturing and operations companies and have also been independent Board members of these companies. We sign the statement solely in our professional capacity and as responsible citizens.” Most of the Committee members have been working in Industry sponsored Telecom Center of Excellence and some of them have been board members of telecom companies. Also, majority of them have worked on baseband, signal processing, network protocol, etc. and have not worked on microwaves, antennas, microwave heating principle, biological effects, etc.) Conclusion: The Committee feels that the recommendations of the 24 faculty members of various IITs appropriately addresses the concerns regarding EMF radiation. (it does address the concerns regarding health hazards of EMF radiation. They completely ignored several thousands of scientific papers, which have reported several health hazards) 2.B.2. Committee, after having carefully gone through the reports as submitted alongwith with the petition and the points raised by Dr. Prof. Girish Kumar, observes that the issues raised by him, about the dangerous ill effects of EMF radiations on human health from cell towers and mobile phones, are an exaggeration, and not based on any conclusive scientific evidence. The dangerous ill effects of EMF radiations on human health from cell towers and mobile phones, are based on large number of scientific evidences. My report to DOT contained 200 references and Bio-Initiative reports have given 3800 scientific references.
  • 48. Page 48 of 70 2. C. In view of the direction of the Hon’ble High Court, Committee also took note of the present status of the implementation of the accepted recommendations of Inter-Ministerial Committee on EMF radiation issued vide OM dt 17th Nov 2011 by DoT. Following is the present status of the implementation of the Office Memorandum: Inter-Ministerial Committee on EMF radiation had also reported hazards of EMF radiations on human health from cell towers and mobile phones, Mobile Handset S/N Recommendations Status of implementation of guidelines I SAR level for mobile handset shall be limited to 1.6 watt/ kg , averaged over a 6 minutes period and taken over a volume containing a mass of 1 gram of human tissue. Guideline has been issued to all Mobile Manufacturers vide para 3(i) of DoT letter no 18-10/2008-IP dt 25 January 2012, to be effective from 1st Sept 2013. II SAR level shall be displayed on the handset. Guideline has been issued to all Mobile Manufacturers vide para 3(ii) of DoT letter no 18-10/2008-IP dt 25 January 2012, effective from 1st Sept 2013. III All cell phone handsets sold in the market in India shall comply with relevant BIS standards and shall be with hand free devices. Guideline has been issued to all Mobile Manufacturers vide para 3(iii) of DoT letter no 18-10/2008-IP dt 25 January 2012, effective from 1st Sept 2013 to adhere to SAR limits of 1.6 watts/Kg. IV SAR value information of the mobile handsets shall be available on the manufacturer’s web site & in the handset’s manual. The information on SAR values shall be made available to the consumer at the point of sale. Guideline has been issued to all Mobile Manufacturers vide para 3(iv) of DoT letter no 18-10/2008-IP dt 25 January 2012 effective from 1st Sept 2013.
  • 49. Page 49 of 70 V Mobile hand set manufactured and sold in India or Imported from other countries shall be checked for compliance of SAR value. Guideline has been issued to all Mobile Manufacturers vide para 3(v) of DoT letter no 18-10/2008-IP dt 25 January 2012, effective from 1st Sept 2013 for importers to adhere to the SAR limits. VI The manufacturers in India shall provide self-declaration of SAR Value of the handset. In respect of imported handset from other countries, the manufacturers apart from self-declaration of SAR shall specify the SAR information in their documents for verification by appropriate authority. Suitable amendment in the Indian Telegraph Rule under Indian Telegraph Act 1985 shall be enacted for strict compliance. Guideline has been issued to all Mobile Manufacturers vide para 3(vi) of DoT letter no 18-10/2008-IP dt 25 January 2012, effective from 1st Sept 2013. Suitable amendment in the Indian Telegraph Rule under Indian Telegraph Act 1985 under consideration for enactment. VII Manufacturer’s mobile handset booklet shall contain the following safety precautions: a) Use a wireless hand-free system (headphone, headset) with a low power Bluetooth emitter. b) Make sure that cell phone has a low SAR c) Keep your calls short or send a text message (SMS) instead. This advice applies especially to children, adolescents and pregnant women. d) Use cell phone when the signal quality is good. e) People having active medical implants should keep the cell phone at least 15 cm away from the implant. Guideline has been issued to all Mobile Manufacturers vide para 3(vii) of DoT letter no 18-10/2008-IP dt 25 January 2012, effective from 1st Sept 2013.
  • 50. Page 50 of 70 VIII List of SAR values of different mobile phones shall be uploaded on DoT/TEC website. The format for such uploading is under finalization. The uploading of SAR values will be done in due course. It should be also mentioned that the limit of 1.6W/Kg is good for 6 minutes with a safety margin of 3 to 4. So, people should not use cell phone for more than 10 to 30 minutes depending upon the SAR value. Also, it should be written that on May 31, 2011, WHO has classified cell phone as possible carcinogen (Class 2B) after Interphone study reported 5,117 brain tumor cases for heavy users. Mobile Base Station (Cell Tower) S/N Recommendations Status of implementation of guidelines IX The exposure limit for the Radio Frequency field (Base Station Emissions) lowered to 1/10th of the existing exposure level as under: Type of exposure Frequency range Power Density (Watt/Sq. mtr) General Public 400- 2000MHz f/2000 2-300 GHz 1 Licenses of the Telecom Service Providers were amended on 30/12/2011 revising the EMF radiation norms as recommended. The revised norms became effective w.e.f 1st September 2012. This limit is very high for 24x7 exposure. It should be less than 0.1 mW/m2 . In the densely populated areas, micro towers (low transmitting power) should be installed instead of macro towers (high power transmitting antennas). X Provision shall be made for continuous online monitoring and display of radiation level in mobile network frequency range at The feasibility of this implementation is being examined. On preliminary study it appears Formatted: Indent: Left: 0 cm, Line spacing: Multiple 1.15 li Formatted: English (United States)
  • 51. Page 51 of 70 prominent places in metro/cities and online data transfer to the central server. that the continuous monitoring may be feasible at limited locations only and it will serve only a limited purpose. XI The mobile service providers apart from self-certification for compliance of radiation norms on EMF exposure shall measure the radiation level in mobile network frequency range of prominent places and display it for information of general public. The service providers should have mobile unit for its measurement wherever necessary This is linked to the para X above. XII A national data base with the information of all base stations, their emission compliance status (i.e. compliant/non- compliant) shall be created and made available in DoT website for public information Such a database is under development. It will be implemented after pilot trials in few states. XIII Uniform guidelines to be formulated at national level to enforce restrictions on establishment/setting up of BTS towers Advisory Guidelines for State Governments for issue of clearance for installation of Mobile Towers have been issued by DoT which are effective from 01.08.2013 These guidelines are not sufficient to protect people from 24x7 radiation from cell towers. XIV An appropriate framework to be created for structural safety clearance for towers set up on roof-tops. This aspect has been taken care in Para 4A(IV) of Advisory Guidelines for State Governments for issue of clearance for installation of Mobile Towers have been issued by DoT which are effective from 01.08.2013 XV In the Master Plan of towns and cities the location for installation of mobile towers shall be identified in consultation with the Appropriate action in DoT is under way.
  • 52. Page 52 of 70 Ministry of Urban Development XVI New technology low power transmitters shall be installed with in-building solutions for the future expansion of telecom network in the country Government has announced ‘National Telecom Policy 2012’ in May 2012 and one of the strategy has been envisaged as: “5.9. To promote use of In-Building Solutions (IBS) and Distributed Antenna Systems (DAS)….” while planning Telecom network. Further, the service providers are mostly using these technologies as per requirement/feasibility to provide coverage inside multi storey buildings. XVII Long term scientific research related to health aspect of EMF radiation exposure from multiple antennas of a shared infrastructure sites and associated technologies in India shall be encouraged Science and Engineering Research Board (SERB) under Department of Science and Technology has constituted a Expert Committee / Task Force in September 2013, to evaluate the R&D proposal on the possible impact of EMF radiation exposure from mobile towers and handsets on life (humans, living organism, flora & fauna and environment) and related initiatives. In addition, Indian Council of Medical Research is also conducting a multi-disciplinary cohort study in Delhi and National Capital Region to find out adverse effects of Radio Frequency Radiation, if any, emitted from cell phone on adult Indian population. (These studies will delay the
  • 53. Page 53 of 70 implementation of stricter radiation norms. Already, there are evidences of health hazards given in 1000's of papers. So, strict guidelines must be implemented immediately and study can go on in parallel for Indian conditions. XVIII A document "Radio waves and safety in our daily life" in regional languages indicating various Dos and Don'ts related to mobile phone users clarifying various myths regarding deployment and use of radio waves shall be created for enhanced customer awareness and to be given to the customer at the point of sale by the mobile service provider. The document has been issued and is placed on the DoT website. The document must be modified to inform dangers of overuse of cell phones and 24x7 exposure to high cell tower radiation. 2.D. Discussions on implementation of various guidelines in India and research work being carried out in the area of “Health Effects from EMF Radiation” 1. Summary of discussion about EMF norms adopted in India: (i) Committee has noted that WHO in its Facts sheet no. 304 of May 2006 has stated that: “International exposure guidelines have been developed to provide protection against established effects from RF fields by International Commission on Non-Ionizing Radiation Protection (ICNIRP,1998) and the Institute of Electrical and Electronics Engineers (IEEE,2005). National authorities should adopt international standards to protect their citizens against adverse levels of RF fields. They should restrict access to areas where exposure limits may be exceeded.” All the above are outdated. In 2011, WHO reported cell phone as possibly carcinogen (Class 2B). What is the point in mentioning earlier reports? Also, there are growing evidences of health hazards in the last few years (as cell
  • 54. Page 54 of 70 phone/tower radiation is cumulative in nature). There are 1000's of scientific papers reporting health hazards but committee chose to ignore. (ii) ICNIRP guidelines have made, inter-alia, following recommendations: a. EMF radiation from tower : ICNIRP has recommended the limit from cell phone tower as “f /200 watt per meter square” where ‘f’ is frequency in MHz.(for 400-2000 MHz) b. EMF radiation from mobile handset: ICNIRP has recommended Specific Absorption Rate (SAR) level of mobile handset as 2 watt per /per kg averaged over mass of 10 gm of tissue. (iii) IEEE guidelines have, inter-alia, made following recommendations: EMF radiation from mobile handset: IEEE has recommended Specific Absorption Rate (SAR) level of mobile handset as 1.6 watt per /per kg averaged over mass of 1 gm of tissue. (iv) Committee notes that India has adopted f/2000 watt per meter square as the EMF radiation limit from cell phone tower which is 1/10th of the ICNIRP recommended limit whereas majority of the countries around the world have adopted the limits prescribed by ICNIRP. (v) Similarly, Committee further notes that with reference to the EMF radiation from mobile handset India has adopted more stringent recommendations of IEEE rather than ICNIRP recommended limits which are 1.6 watt per kg averaged over mass of 1 gm of human tissue, as against the ICNIRP
  • 55. Page 55 of 70 recommended limit of 2 watt per kg averaged over mass of 10 gm of human tissue. (vi) Committee also further notes that though there are some isolated examples of a few countries or counties / local bodies on a country adopting lower radiation norms from cell phone towers but as per the available information as far as SAR values are concerned these countries have adopted the norms of ICNIRP. (vii) The Committee also noted that in case of EMF radiation level from BTS/Tower become too low at a location, the EMF radiation power from mobile phone, which is in kept near to head, increases. (viii) India is among the very few countries to adopt the precautionary approach and probably the only country to adopt stringent SAR values for mobile handsets alongwith 1/10th of ICNIRP recommended norms as limit for radiation from cell phone towers, as an abundant precaution. These guidelines are not sufficient to protect people from 24x7 radiation from cell towers. It must be reduced to 0.1 mW/m2. In other countries, even though they adopted ICNIRP guidelines, they use micro towers (low transmitting power) In the densely populated areas instead of macro towers (high power transmitting antennas). In the FCC document OET56, on Page 21, it is mentioned that in urban area, radiated power of 0.5 -1W or less is commonly used. It should be also mentioned that for handsets, the limit of 1.6W/Kg is good for 6 minutes with a safety margin of 3 to 4. So, people should not use cell phone for more than 10 to 30 minutes depending upon the SAR value. Also, it should be written that on May 31, 2011, WHO has classified cell phone as possible carcinogen (Class 2B) after Interphone study reported 5,117 brain tumor cases for heavy users. 2. Implementation of EMF Norms and discussion about the research reports:
  • 56. Page 56 of 70 (i) Committee also notes that enforcing compliance of the recommended norms is an important aspect in limiting the EMF radiation exposure and keeping general public areas around the tower safe. (ii) In order to implement the EMF radiation norms, DoT has prescribed a procedure to be followed by the telecom service providers. To oversee the implementation, DoT through its 34 field units, known as TERM units, takes self-certificates for compliance of EMF norms by the operators and conducts regular audit of the EMF radiation exposure from the mobile towers as per the prescribed procedure. (Self certification is not good. Also, audit of only 10% of sites is done). (iii) For violation of the EMF norms by the telecom operators, if any, penalties are levied and BTSs may also be shut down in case violation persists. (iv) Committee also noted that DOT has already audited physically more than 80,000 BTSs so far all over the country and violation of prescribed EMF norms was found in 152 BTSs out of which 127 BTSs were in Mumbai alone. Appropriate action has already been taken by DOT in these cases. The list of violators must be uploaded and what action has been taken. (v) In order to increase the deterrence, Department of Telecom, recently on 20th November 2013, has made the compliance norms more stringent. The penalty for non-compliance to EMF norms by mobile operators has been increased from Rs. 5.00 lakh to Rs. 10.00 lakh. This penalty is applicable per occasion per mobile operator per site if the tower site is shared by more than one operator and is applicable to all the operators sharing the tower site. (Norms must be reduced) (vi) EMF radiation limits from cell tower and mobile handsets have been prescribed by DoT taking into account both thermal and non-thermal/ biological effects of EMF radiation. This is not correct as stated above.
  • 57. Page 57 of 70 (vii) Committee notes with satisfaction the efforts made by Department of Telecom in adopting the most precautionary approach for limiting the EMF radiation from mobile towers in addition to adoption of most stringent SAR level for mobile handsets in India. Further the penalty on non-compliant telecom service providers has been doubled to Rs. 10.00 lakh per site per occasion per operator. (Norms must be reduced as stated earlier) (viii) Committee also noted that in reply to a online question, WHO on 20.9.13 has mentioned: “…………Because exposure to the radiofrequency (RF) fields emitted by mobile phones is generally more than a 1000 times higher than from base stations, and the greater likelihood of any adverse effect being due to handsets, research has almost exclusively been conducted on possible effects of mobile phone exposure. THIS IS VERY IMPORTANT, it implies that base station radiation is 1/1000 of mobile phones. We have measured radiation density of many mobile phones, when they are in the talk mode, and it is around 100 mW/m2 , so 1/1000th will be 0.1mW/m2 . Thus, the safe radiation norm should be around 0.1mW/m2 and not 450mW/m2 . This is also the recommendation of Bio-Initaitve Reports, Austrian Medical Association, and based on my interaction with 100's of people who sufferred due to high cell tower radiation. People have reported headaches, sleep disorder, memory loss, joint problems, infertility, mis-carriages, cardiovascular problems, cancer, etc.……………………… ……………………… WHO has further concluded that While an increased risk of brain tumours from the use of mobile phones is not established, the increasing use of mobile phones and the lack of data for mobile phone use over time periods longer than 15 years warrant further research of mobile phone use and brain cancer risk. In particular, with the recent popularity of mobile
  • 58. Page 58 of 70 phone use among younger people and, therefore, a potentially longer lifetime of exposure, WHO has promoted further research on this ground and is currently assessing the health impact of RF fields on all studied end points. This information is in public domain on the website of WHO. However, a copy of the reply to the online question by WHO is enclosed as Annexure-V. The second paragraph should be read in the light of first paragraph. (ix) Committee, after going through the reply of an online question by WHO dated 20.9.2013, notes the finding of WHO that exposure to the radiofrequency (RF) fields emitted by mobile phones is generally more than a 1000 times higher than from base stations and there is greater likelihood of any adverse effect being due to handsets. And that research has almost exclusively been conducted on possible effects of mobile phone exposure. Committee is of the opinion that in the light of WHO report and the fact that India has already adopted precautionary approach by reducing the limit of EMF exposure from both mobile towers and mobile phones, present prescribed norms are adequate. Present norms are as mentioned below: a) For Cell Towers: 1/10th of ICNIRP limit as the prescribed limit of EMF radiation from cell tower. This still very high b) For Mobile Phones: SAR values adopted in India are 1.6 Watt/Kg averaged over 1gm tissue, which are most stringent. limited use must be emphasized.
  • 59. Page 59 of 70 The prescribed EMF exposure limits in India are well within the safe limits. no, these limits are high for 24x7 exposure (x) WHO in its Fact Sheet No. 193 of June 2011 (ANNEXURE-VI), has stated that there are some indications of an increased risk of glioma for those who reported the highest 10% of cumulative hours of cell phone use, although there was no consistent trend of increasing risk with greater duration of use. The researchers concluded that biases and errors limit the strength of these conclusions and prevent a causal interpretation. Based largely on these data, IARC (an agency of WHO) has classified radiofrequency electromagnetic fields as possibly carcinogenic to humans (Group 2B), a category used when a causal association is considered credible, but when chance, bias or confounding cannot be ruled out with reasonable confidence. WHO has further stated that a large number of studies have been performed over the last two decades to assess whether mobile phones pose a potential health risk. To date, no adverse health effects have been established as being caused by mobile phone use. They found limited evidence and that's why it was classified as Possibly carcinogen (Class 2B). If there was no adverse health effect, they would have classified as Class 3 or 4. Committee also noted that, in fact, substances, mixtures and exposure circumstances classified by the International Agency for Research on Cancer (IARC) as ‘Group 2B’, inter-alia, include coffee, Aloe vera (whole leaf extract), Pickled vegetables (traditional in Asia), Talc-based body powder etc. (source IARC Monographs) Let me ask, how many times people eat pickles in a day, may be, maximum 2 to 3 times; how many times people drink coffee, may be maximum 2 to 5 cups of coffee per day. Similarly, using cell phones for up to 10 to 30 minutes may be safe depending upon SAR value of the cell phone. Interphone study released in May 2010 reported 5,117 brain tumor cases and stated that people who use cell phones for 30 minutes per day over a duration of 8 to 10 years, have doubled to quadrupled chances of getting brain tumor, and that's why it was classified as Class 2B. Use of cell phones is a personal choice but what about people who live in the vicinity of cell towers, they are exposed to the radiation 24x7.
  • 60. Page 60 of 70 (xi) Committee also deliberated in detail the various studies and information circulated through email by various Members of the Committee. These studies include ICNIRP report, Bio-Initiative report, FCC guidelines, report of Health Protection Agency (United Kingdom), EMF exposure limit comparison and various other studies related to effects of EMF radiation on human health. (xii) With regard to Bio-Initiative report 2007, committee noted the statement issued in year 2009 by the Committee on Man and Radiation (COMAR) which is a technical committee of the Engineering in Medicine and Biology Society (EMBS) of the Institute of Electrical and Electronics Engineers (IEEE), an international standard making body. COAMAR is primarily working in the area of biological effects of non-ionizing electromagnetic radiation, including radiofrequency (RF) energy. explaination is given below. COMAR submitted a statement in 2009 on BioInitiative report titled: “COMAR Technical Information Statement: Expert reviews on potential health effects of radiofrequency electromagnetic fields and comments on the BioInitiative Report”. (Annexure-VII) Extract of this statement is as below: “This report summarizes the conclusions from several major reports and comments on the markedly different conclusions in the BioInitiative Report (abbreviated BIR below). Since appearing on the Internet in August 2007, the BIR has received much media attention but, more recently, has been criticized by several health organizations (see Section titled “Views of health agencies about BIR”). COMAR concludes that the weight of scientific evidence in the RF bioeffects literature does not support the safety limits recommended by the BioInitiative group. For this reason, COMAR recommends that public health officials continue to base their policies on RF safety limits recommended by established and sanctioned international organizations such as the Institute of Electrical and Electronics Engineers International Committee on Electromagnetic Safety
  • 61. and the International Commission on Non which is formally related to the World Health Organization.” Further, committee also noted that Indian (ICMR), on critical examination of the Bio observed that the report is not based on multi disciplinary weight and there is no balanced reflection of the current state of scientific knowledge. However, further study is needed to arrive at a conclusion about the potential health effects of EMF radiation. It was also noted that, WHO, after studying approximately 25,000 studies over past 30 years has concluded that current evidence does not confirm the consequences from exposure to EMF radiation. WHO report. The Bio-Initiative Report 2012 is prepared by 29 scientists and health experts from 10 countries and was uploaded in Jan. 2013 to create awareness. It is an update of Bio published by Bio-Initiative Working Group effects and adverse health effects from EMF exposures. They recommended safe radiation density of 1 milliwatts/m 2 for outdoor and 0.1 milliwatts/m Bio-Initiative 2012 assessed 1800 new research papers (from 2006 to 2011) and mentioned that Bio clearly established and occur at very low levels of exposure to electromagnetic fields and radiofrequency radiation. Even at 0.03 milliwatts/m 2 , researchers have in children and adolescents; and sleep disturbances, headaches and concentration problems in adults. Public safety standards are 1,000 – 10,000 or more times higher than levels now comm studies to cause bio-effects. Cell phone/tower industry criticized the report citing other reports and references. However, according to me, Initiative Reports of 2007 and 2012 are the most authentic reports on this subject, giving references of 3800 research papers, written by more than 1000 scientists, reviewed by equally large number of experts and published in the prestigious journals. Also, Guidelines of Austrian Medical Association adopted on 3rd March 2012 in Vienna (xiii) Page 61 of 70 and the International Commission on Non-Ionizing Radiation Protection, which is formally related to the World Health Organization.” Further, committee also noted that Indian Council of Medical Research (ICMR), on critical examination of the Bio-initiative 2012 Report, has observed that the report is not based on multi disciplinary weight and there is no balanced reflection of the current state of scientific knowledge. further study is needed to arrive at a conclusion about the health effects of EMF radiation. It was also noted that, WHO, after studying approximately 25,000 studies over past 30 years has concluded that current evidence does not confirm the existence of any health consequences from exposure to EMF radiation. This statement is taken Initiative Report 2012 is prepared by 29 scientists and health experts from 10 countries and was uploaded in Jan. 2013 to create awareness. It is an update of Bio-Initiative Report 2007, which was Initiative Working Group that looked at more than 2,000 peer reviewed studies documenting bio effects and adverse health effects from EMF exposures. They recommended safe radiation density of 1 for outdoor and 0.1 milliwatts/m 2 for indoor continuous exposure. 2012 assessed 1800 new research papers (from 2006 to 2011) and mentioned that Bio clearly established and occur at very low levels of exposure to electromagnetic fields and radiofrequency radiation. , researchers have reported headaches, concentration difficulties and behavioral problems in children and adolescents; and sleep disturbances, headaches and concentration problems in adults. Public safety 10,000 or more times higher than levels now commonly reported in mobile phone base station Cell phone/tower industry criticized the report citing other reports and references. However, according to me, Reports of 2007 and 2012 are the most authentic reports on this subject, giving references of 3800 research papers, written by more than 1000 scientists, reviewed by equally large number of experts and published in the nes of Austrian Medical Association adopted on 3rd March 2012 in Vienna Ionizing Radiation Protection, which is formally related to the World Health Organization.” Council of Medical Research initiative 2012 Report, has observed that the report is not based on multi disciplinary weight and there is no balanced reflection of the current state of scientific knowledge. further study is needed to arrive at a conclusion about the It was also noted that, WHO, after studying approximately 25,000 studies over past 30 existence of any health This statement is taken from older Initiative Report 2012 is prepared by 29 scientists and health experts from 10 countries Initiative Report 2007, which was ed at more than 2,000 peer reviewed studies documenting bio- effects and adverse health effects from EMF exposures. They recommended safe radiation density of 1 2012 assessed 1800 new research papers (from 2006 to 2011) and mentioned that Bio-effects are clearly established and occur at very low levels of exposure to electromagnetic fields and radiofrequency radiation. reported headaches, concentration difficulties and behavioral problems in children and adolescents; and sleep disturbances, headaches and concentration problems in adults. Public safety only reported in mobile phone base station Cell phone/tower industry criticized the report citing other reports and references. However, according to me, Bio- Reports of 2007 and 2012 are the most authentic reports on this subject, giving references of 3800 research papers, written by more than 1000 scientists, reviewed by equally large number of experts and published in the nes of Austrian Medical Association adopted on 3rd March 2012 in Vienna are: Formatted: Font: 11 pt Formatted: Font: 11 pt Formatted: Font: (Default) Arial,Arial, 14 pt
  • 62. Page 62 of 70 (xiv) Further, committee also noted that DoT has issued “Precautionary guidelines for the mobile users” to increase public awareness,. In addition, DoT has also published advertisements in National & Regional Newspapers for creating awareness among public for ensuring safety from EMF radiations emitted from Mobile Towers & handsets. Further, for the information of the general public, a hand book on “Mobile Communication - Radio Waves & Safety” has also been issued. These documents are available on the website of DoT also. (Annexure-VIII) some of the guidelines issued by DOT are confusing and convey there are no health hazards, whereas there are 1000's of papers, which have reported health hazards. 2.E. Other Discussions: (i) Committee noted that as part of professional ethics, a practice is being followed by all the professionals before publishing any report/ newsletter in public domain to make a disclosure about their commercial business interest or the commercial business interest of their close relatives and family members. Committee noticed that Prof. (Dr. Girish Kumar) has not made any such disclosure about the studies being conducted by him/ reports submitted by him or on the newsletters being published by him on the issue of health effects from EMF radiation. Though Prof. (Dr.) Girish Kumar has agreed to submit a proper disclosure on his work related to EMF radiation initially but he later on refused to give any such disclosure. However, Prof.(Dr.) Girish Kumar has stated that the information given in his newsletter be considered as his disclosure. The other members of the Committee feels that he should have specifically disclosed his family’s commercial interest in companies involved in manufacturing / dealing with EMF shielding products. In my second newsletter on cell phone/tower radiation hazards and solutons, it is clearly mentioned on Page 5 under point 6. Father - Daughter Team - Radiation Solutions The cell operators and their associates say that Prof. Girish Kumar is telling about harmful effects of radiation because his daughter, Neha Kumar, has a company named, "NESA Radiation Solutions Pvt. Ltd", which sells radiation shielding solutions. My reply was: On every forum and at all the places, I always say adopt better radiation norms and reduce the transmitted power. If they reduce the transmitted power, then
  • 63. Page 63 of 70 who will need the shielding solutions? This newsletter has been openly circulated to large number of people, so I have openly disclosed the facts. (ii) Committee wants to highlight that Dr. (Prof.) Girish Kumar had circulated an email to all the committee members, casting aspersions and ascribing bias against them which was strongly objected to by the members (copy of minutes of first meeting of the committee are enclosed as annexure-I). Most of the members were of the view that it amounts to undermining the premier institutions and disagreed with Prof. Girish Kumar’s prejudiced stance at the very outset. Prof. (Dr.) Girish Kumar refused to attend and participate in the meetings of the committee despite pursuance by DOT and did not attend the first meeting. It is worth mentioning that while formulating the committee, nominations were asked from the Head of the organizations and based on the nominations, so received, the committee was constituted in line with the directions of the Hon’ble High Court. I have given below the email sent by me: Dear Shri Rama Shankar, Recd. your following email with the attachement reagrding Meeting Notice of the committee constituted on the direction of Honourable High Court Allahabad on 25.09.2013 at 3.30 PM at Sanchar Bhawan. I saw the names of the 13 committee members. I am extremely disappointed to see the names, majority of whom are pro DOT norms (in a way favourable to high radiation emitted by cell operators) of 450 mW/sq.m to 1000 mW/sq., whereas people are having health problems even at a level
  • 64. Page 64 of 70 of 1 mW/sq.m within 5 to 10 years. According to Bio-Initiative report 2012, for 24x7 exposure, safe level must be less than 0.1 mW/sq.m. For example (the serial numbers are according to the file attached: 1. Shri Sirohi - from DOT 4. Prof. Ranjan Mallik, IITD - pro cell operators 5. Prof. SN Sinha, IIT Roorkee - says no health problems 7. Dr. RS Sharma, ICMR, Delhi - will say we are carrying out studies, and will give the results in 2 years. 10. SS Kohli, DST, Delhi - I had attended expert committee meeting organized by him and chaired by DST Secretary on July 3, 2012. There were 13 people in the meetined and 4-5 people mentioned about various health hazards and yet it was concluded there is no conclusive evidence. In their subsequent expert committee meeting, I was not even invited. 11. UK Srivastava, TEC - known to favour high radiation norm 12. Nitin Jain - from DOT 13. Atul Kumar Chaudhary - from DOT Thus, out of 13 members, 8 are known to favour DOT norms (high radiation). based on my prior experience mentioned above, I do not want to attend this closed door meeting, where my view-points will be outnumbered. I can come if and only if, it is an open door meeting, where media and concerned people are invited, who have sufferred due to high cell tower radiation, and then everybody's view points are noted and recorded. I am willing to give presentation at the HC, Allahabad in front of the honourable Judge, lawyers and concerned citizens. With regards. (Girish Kumar)
  • 65. Page 65 of 70 It can be noted from the report, committee members proved my apprehension as right. The language used by the committee members is not appropriate. Instead of trying to come out with a scientific and balanced report to protect, people, birds, animals, plants, trees, etc., the entire focus of the members turned out to prove Prof. Girish Kumar wrong. Is this the way to convene a very prestigious meeting, which was formed due to Allahabad HC. After the first meeting, one of the members called me that I should have come as other people are planning to file contempt of court against me. I am a law abiding citizen, so I agreed to attend these meetings. However, it has been the most horrifying experience for me to attend subsequent meetings, where one or other members constantly tried to interrupt me, ridicule me, and so on. (iii) Committee also noted that Prof. (Dr.) Girish Kumar in his newsletter of October 2013 while responding to some allegation has admitted to his commercial interest in the family business of ‘radiation shielding solutions’.The committee observed that his daughter Ms. Neha Kumar is selling ‘Radiation Shielding Solutions’ through her company named “NESA Radiation Solutions Pvt. Ltd.” The members of the Committee noted that on one hand he is spreading misinformation & creating misconceptions and unfounded apprehensions in the mind of public by sensationalizing and blowing out of proportion the effects of EMF radiation, on other side he is promoting his family’s business on related products (which do not even follow any National/International standards) thus throwing professional ethics to the winds. Again I want to mention: On every forum and at all the places, I always say adopt better radiation norms and reduce the transmitted power. If they reduce the transmitted power, then who will need the shielding solutions? This newsletter has been openly circulated to large number of people, so I have openly disclosed the facts. Formatted: Font: (Default) Calibri, 11 pt, Not Bold Formatted: Indent: Left: 0 cm, First line: 0 cm, Line spacing: Multiple 1.15 li, Don't adjust space between Latin and Asian text, Don't adjust space between Asian text and numbers
  • 66. Page 66 of 70 3. Observations and Recommendations of the Committee for taking necessary precautions with respect to EMF radiation from mobile towers and mobile phones. 3.A. OBSERVATIONS: I. The Committee has carefully examined all the submissions of the petitioner, through the presentation of Prof. (Dr.) Girish Kumar. On the basis of scientific evidences, studies and reports available, it has been found that there is no conclusive evidence about the stated dangers of EMF radiation from mobile BTS tower as raised by the petitioner. First of all, no conclusive evidence does not mean no evidence. I provided them 1000's of references but committee decided to ignore these due to the reasons best known to them. As regards the possible health hazards of EMF radiation from mobile phones, WHO has concluded in its Fact Sheet No. 193, year 2011 that a large number of studies have been performed over the last two decades to assess whether mobile phones pose a potential health risk. To date, no adverse health effects have been established as being caused by mobile phone use. Further studies are ongoing in different parts of the world to assess possible health effects of mobile phone exposure. WHO classified cell phone as possibly carcinogen (Class 2B). It did not classify it as Class 3 or 4. In addition, in reply to an online question, WHO on 20th September, 2013 has mentioned that Studies to date provide no indication that environmental exposure to RF fields, such as from base stations, increases the risk of cancer or any other disease. Further, it is also mentioned that Scientists have reported other health effects of using mobile phones including changes in brain activity, reaction times, and sleep patterns. These effects are minor and have no apparent health significance. More studies are underway to try to confirm these findings. Only second paragraph of the WHO reply is included. First part
  • 67. Page 67 of 70 mentions that exposure to the radiofrequency (RF) fields emitted by mobile phones is generally more than a 1000 times higher than from base stations and there is greater likelihood of any adverse effect being due to handsets. THIS IS VERY IMPORTANT, it implies that base station radiation is 1/1000 of mobile phones. We have measured radiation density of many mobile phones, when they are in the talk mode, and it is around 100 mW/m2 , so 1/1000th will be 0.1mW/m2 . Thus, the safe radiation norm should be around 0.1mW/m2 and not 450mW/m2 . II. The Committee also took note of the actions taken by the Department of Telecommunication in view of the accepted recommendations of the Inter- ministerial Committee. It has been observed by the Committee that the Department has taken adequate steps to impose stricter precautionary limits for EMF radiation from mobile towers as well as from the mobile phones. Much more stricter norms must be implemented. III. The committee observed that DoT has taken adequate steps in regard to granting of permission for siting of mobile towers in its recent guidelines to State governments and TERM cells in different licence service areas effective from 01-08-2013. Further, stricter ‘SAR’ values have been specified for mobile phones being sold in India, effective from 01-09-2013. DOT has not taken adequate steps to safeguard people. IV. Also, in order to make the deterrence stronger, the penalty for violation of prescribed stricter EMF norms from BTS tower by telecom service providers has been increased from Rs. 5 Lakhs to Rs. 10 Lakhs per BTS, per incidence per operator w.e.f. 20th November, 2013. V. Presently some organisation including ICMR, SERB are making efforts to scientifically investigate and mitigate the possible health hazard potential of EMF radiation keeping in view the country specific aspects such as population density, gGeographical condition, Indian society context and the eco-system etc., there is a need to further speed up the scientific studies/research in order to generate credible scientific data/evidences. These studies are extremely
  • 68. Page 68 of 70 essential in order to assess the further need to improve the EMF exposure norms based on the credible scientific evidences. These studies will take several years. Stricter radiation norms must be implemented immediately based on 1000's of studies available. Study may be done in parallel but after reducing the norms. VI. The Committee repeatedly requested Prof. Girish kumar to provide scientific evidence / data in support of his claims. However, he did not provide any scientific documents in support of his arguments and stated that the he does not agree with the conclusions of the committee. He was also given ample opportunity to question the scientific rationale behind the conclusion / observations of the committee but he did not. I had provided them list of 200 papers in my DOT report and also list of 1000's of papers, which reported health hazards. Most of the time, they will produce other papers, which mention there are no problems. In all the meetings, it appeared that majority of the members are the mouth pieces of cell tower industry, who is trying to safeguard their business interest. 3.B. RECOMMENDATIONS: I. The Department of Telecom should continue the extensive audit of the self - certificates being submitted by the Telecom Service Providers in order to ensure compliance to the prescribed stricter norms of EMF radiation from BTS tower. Why self certification? II. The Department of Science and Technology and Indian Council of Medical Research (ICMR) should carry out / facilitate extensive studies, on the Indian conditions with special focus on prolonged use of mobile phone, to conclusively determine sensitivity of EMF Radiation / possible health hazard risk of EMF radiation, which at present is not proven. These Indian specific scientific studies should aim at generating scientifically credible data and evidences by involving Ministry of Science and Technology, ICMR, Ministry of Environment & Forest, DoT and other relevant organisation. The Government of India should make
  • 69. Page 69 of 70 available funds to ensure extensive long term/short term research and studies on possible health effects of EMF radiation on humans. It is a good idea, however, we must adopt lower norms immediately and studies can be taken in parallel. III. Department of Telecom has already taken measures to create awareness among public by issuing “Precautionary guidelines for the mobile users” and publishing advertisements in National & Regional Newspapers for ensuring safety from EMF radiations emitted from Mobile Towers & handsets for the information of the general public. A hand book on “Mobile Communication - Radio Waves & Safety” has also been issued by Department of Telecom. These measures, inter-alia, include: (i) Frequently asked questions (FAQ) (ii) Myths and Facts (iii) Precautionary guidelines for Mobile Users These precautionary guidelines, inter-alia, include the following precautions: • Keep distance – Hold the cell phone away from body to the extent possible • Use a headset (or ear bud) to keep the handset farther from your head. • Do not press the phone handset against your head. • Use a wired headset • Limit the length of mobile calls. • Use text as compared to voice wherever possible. • Put the cell phone on speaker mode. etc. According to the committee members, if there are no health hazards, then why take above precautions. This means that they agree there are problems and want to use precautions. Committee recommends that there is a need to step up effort by DOT to spread public awareness and allay undue apprehensions in regard to possible health effects of EMF radiation. This can be done through print media/electronic media and other communications channels and tools along with conducting market research / survey, workshops and seminars etc. Awareness should be created to warn people about overuse of cell phone and living in the vicinity of high cell tower radiation. IV. Annual discussion, meetings/seminars should be conducted by the Government by inviting experts from various academic and research institutions for continual
  • 70. Page 70 of 70 evaluation of scientific evidence published worldwide with an aim to monitor the progress in research on the effects of EMF radiation. V. In order to get latest updates on EMF radiation related issues, DoT should actively participate in the deliberations of various International standards bodies, including WHO, involved in the study of EMF radiation. Department of Telecom should create national EMF web portal to provide public access to the status of compliance, of the prescribed norms, of all BTSs/ mobile towers in the country and related relevant information. . Awareness must be created to inform people about health hazards of overuse of cell phones. Also, micro towers (low power transmitters) should be installed in densely populated are, so that people living in the vicinity of towers are not exposed to high cell tower radiation. VI. (Dr. S.N. Sinha) (Professor, IIT Roorkee) Member (Dr Ajit Kumar Chaturvedi) (Professor, IIT Kanpur) Member ( Dr Ranjan Mallik) (Professor, IIT Delhi) Member (Dr. Vivek Tandon) (AIIMS, New Delhi) Alternate Member (Dr. Girish Kumar) (Professor, IIT, Mumbai) Member ( Dr. R.C. Murthy) (Chief Scientist,IITR Lucknow) Member (Dr. R. S. Sharma) (ICMR, New Delhi) Member (Dr. Ajoy Chakraborty) (Professor, IIT Kharagpur) Member (Shri S. S. Kohli) (SERB New Delhi) Member (Shri U. K. Srivastava) (DDG, TEC, DoT) Member (Shri Nitin Jain) (DDG CS, DoT) Member (Shri Rama Shankar Ram) (Director (CS-TP), DoT) Alternate Member Convener (Shri S. S. Sirohi) (Sr. DDG (TERM), DoT) Chairman