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

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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

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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

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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.

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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).

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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.

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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,

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"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

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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

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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

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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

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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

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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

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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

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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

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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,
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,
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

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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

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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

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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.

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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

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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

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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

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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

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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.

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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

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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

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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

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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.)

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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.

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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

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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

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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

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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)

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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,

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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

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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

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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

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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

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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.

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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.
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.
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.
Manufacturers vide para 3(iv) of DoT letter
no 18-10/2008-IP dt 25 January 2012
effective from 1st
Sept 2013.

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V Mobile hand set manufactured and
sold in India or Imported from other
countries shall be checked for
compliance of SAR value.
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.
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.
Manufacturers vide para 3(vii) of DoT letter
no 18-10/2008-IP dt 25 January 2012,
effective from 1st
Sept 2013.

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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
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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.

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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

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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

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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

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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:

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(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.

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(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

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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.

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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.

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(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

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
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,
Further, committee also noted that Indian Council of Medical Research
(ICMR), on critical examination of the Bio-initiative 2012 Report, has
further study is needed to arrive at a conclusion about the
health effects of EMF radiation.
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
2
for indoor continuous exposure.
2012 assessed 1800 new research papers (from 2006 to 2011) and mentioned that Bio
, researchers have reported headaches, concentration difficulties and behavioral problems
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
nes of Austrian Medical Association adopted on 3rd March 2012 in Vienna
Ionizing Radiation Protection,
Council of Medical Research
initiative 2012 Report, has
further study is needed to arrive at a conclusion about the
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-
2012 assessed 1800 new research papers (from 2006 to 2011) and mentioned that Bio-effects are
reported headaches, concentration difficulties and behavioral problems
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
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

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

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

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)

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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
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line: 0 cm, Line spacing: Multiple 1.15
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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

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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

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

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