Submission to the Senate Environment, Communications, Information Technology and the Arts Committee Reference: EME Inquiry Index Page 3 Acronyms Executive Summary 4 Introduction 7 Reference (a) 9 Reference (b) 11 Reference (c), (d) and (e) 15 Appendix A AMTA Appendix B How the mobile phone network operates Appendix C Economic and social benefits of mobile telephony Appendix D The future of mobile telecommunications Appendix E The precautionary principle and prudent avoidance Appendix F The use of hands-free kits Appendix G References Appendix H Electronic Mail to Dr John Moulder, Professor of Radiation Oncology, Radiology and Pharmacology/Toxicology at the Medical College of Wisconsin Page 2 20 21 23 27 29 32 33 34 Acronyms ACA ACIF ALARA AMTA ARPANSA CDMA CMTS DISPLAN dB EC EME EMF EMR FCC GDP GPRS GSM GST IARC ICNIRP IMT 2000 IRPA IT NHMRC NRPB RF RF dosimetry SAR TE/7 3G UNEP WHO WTO Australian Communications Authority Australian Communications Industry Forum As Low As Reasonably Achievable Australian Mobile Telecommunications Association Australian Radiation Protection and National Safety Agency Code Division Multiple Access Cellular Mobile Telephone System Disaster Plan Decibel European Community Electromagnetic Energy Electromagnetic Field Electromagnetic Radiation Federal Communications Commission (USA) Gross Domestic Product General Packet Radio Service Global System for Mobile Communications Goods and Services Tax International Agency for research on Cancer International Commission on Non-Ionising Radiation 3rd generation mobile services International Radiation Protection Association Information Technology National Health and Medical Research Council National Radiological Protection Board (UK) Radiofrequency The measurement or calculation of RF dose Specific Absorption Rate Standards Australia committee that was responsible for drafting the AS2772.1 RF exposure Standard. 3rd generation mobile services United Nations Environment Program World Health Organisation World Trade Organisation Please Note: In this submission, the terms electromagnetic energy ('EME') and electromagnetic radiation ('EMR') are used interchangeably. The mobiles industry, like the United States Federal Communications Commission (FCC), uses the term electromagnetic energy to avoid confusion between ionizing and non-ionizing radiation. Both terms are scientifically equivalent as the term 'radiation' simply means 'the transfer of energy'. Page 3 Executive Summary 1. The Australian Mobile Telecommunications Association (AMTA) is the national representative body for the mobile telecommunications industry. It represents carriers, manufacturers, retailers and associated industries. Membership includes transnational and Australian firms servicing around 8 million mobile subscribers. 2. Consumer and community confidence in mobile products and services are important to the long-term success of the industry. Community uncertainty on health and other issues is necessarily of concern to the industry. In that context, the Senate Inquiry is a timely and welcome opportunity to address community and industry issues in an inclusive, public process. AMTA supports the Senate Environment, Communications, Information Technology and the Arts Committee Reference: EME Inquiry (Senate Inquiry) process as a means of facilitating open debate on specific electromagnetic energy (EME) issues including national and international research and standards. 3. The health effects of EME are a major area of interest for the Senate Inquiry. The National Health and Medical Research Council (NHMRC) administers a government funded research program into EME underwritten by a levy on the carriers. 4. AMTA supports the continued funding of the research program. This research will have greater value if it continues to be consistent with, and in support of, the global World Health Organisation (WHO) and International Agency for Research on Cancer (IARC) assessments into the safety of EME. 5. If additional high quality research is identified through the NHMRC, AMTA would support additional funding for research of those identified projects. 6. AMTA also supports a Government sponsored, independent public information program, funded separately from the research program, to ensure that the community has ready access to reliable and accurate information about EME. 7. Media and community attention has been drawn to speculation about whether mobile radio transmissions have a health impact, particularly with regard to cancer. It is the assessment of the world’s leading expert and health advisory bodies that there is no substantiated scientific evidence that either using a mobile phone or living near a mobile phone base station is harmful to human health. 8. This assessment has been made by numerous international authorities including the International Commission for Non-Ionising Radiation (ICNIRP), the European Commission (EC) Expert Group, WHO, the Royal Society of Canada and most recently the UK’s Stewart Inquiry. This is additional to independent experts in the field such as Moulder, Brusick, Elwood and others Page 4 9. Industry standards offer benefits to business, consumers and the general public. These include product efficiencies, enhanced safety and security, more efficient public controls, and interoperability. There are established international procedures, which are followed in Australia, to ensure that the standard setting process is consultative, inclusive of relevant expertise, consistent with international developments and developed in the spirit of furthering the common public interest. 10. In Australia, the TE/7 Committee responsible for drafting the Australian Standard, AS2772.1, for human exposure to RF emissions only just failed to reach the requisite 80% consensus agreement. The AS2772.1 Standard was subsequently withdrawn, leaving Australia with no official RF exposure Standard. To fill this vacuum, the Australian Communications Authority (ACA) mandated its own RF exposure Standard for telecommunications, based on the limits of the previous AS2772.1 Standard. 11. The Federal Government through the ACA has entrusted the development of a new RF exposure Standard to the Australian Radiation Protection and National Safety Agency (ARPANSA). AMTA supports the Government’s action and recognises ARPANSA’s broad based representation which includes industry expertise. The Australian Communications Industry Forum (ACIF) is developing an industry code for the Deployment of Radio Communications Infrastructure. The two processes complement each other. 12. AMTA supports a process of standards development in Australia that continues to be consultative, inclusive of all relevant expertise and based on the most recent substantiated, world-wide scientific research. 13. AMTA considers that appointments to standards development bodies or scientific advisory bodies should be made on the basis of relevant experience and expertise rather than on the basis of representation of interest groups. 14. With the absence of agreement on Standards Australia TE/7 Committee, the Government acted responsibly in seeking a new standard from ARPANSA and requesting an industry code from ACIF on the siting of new infrastructure. 15. The composition of the ARPANSA committee overseeing the development of the new Australian exposure standard has appropriate participation and takes into account relevant expertise. 16. The harmonisation of standards on a global basis is a worthwhile objective and AMTA would welcome a replacement Australian standard being developed within the guidelines recommended by the ICNIRP. The ICNIRP guidelines are based on the need to avoid known adverse health effects and provides a safety factor of up to 50. Page 5 17. Any risk reducing policy which has the consequence of limiting the affordability of mobile phones or reducing the community’s access to mobile phone services would need to be balanced against the known benefits of mobile phones, including the many lives saved each year by the technology. AMTA cautions against any trade off between known public safety benefits and unproven low level risks (refer Appendix E for full discussion). 18. AMTA considers that the Precautionary Principle as defined by the WHO represents a sensible and scientifically based approach. 19. There are broader economic and social benefits associated with mobile telephony that AMTA draws to the Senate Inquiry’s attention. Mobile telephony is now a A$5 billion business directly employing more than 64,000 Australians. It has a significant impact on business efficiencies right across the economy but with particular emphasis on labour productivity, labour mobility and with a positive (if unmeasurable) effect on GDP growth (refer Appendix C for full discussion). 20. Mobile communications offer a range of social benefits that Australians now take for granted. Other advantages are in personal safety, enhanced personal and community security, emergency situations and improved disaster planning. 21. Mobile telephony continues to undergo rapid technological change. Third generation technology will extend the range of readily available services from voice and messaging to data, graphics, video and other internet based products. The exponential growth in the uptake of mobile telephony, which in some developed markets is exceeding 60%, demonstrates the strong community desire for the ability to communicate at any time and anywhere. (refer Appendix D for full discussion) Page 6 Introduction 22. On 8 December 1999, the Senate agreed to refer the following matters to the Environment, Communications, Information Technology and the Arts References Committee for inquiry (a) an examination of the allocation of funding from the Commonwealth's $4.5 million fund for electro-magnetic radiation research and public information; (b) a review of current Australian and international research into electromagnetic radiation and its effects as it applies to telecommunications equipment, including but not limited to, mobile telephones; (c) an examination of the current Australian Interim Standard [AS/NZS 2772.1 (Int):1998], as it applies to telecommunications; (d) an examination of efforts to set an Australian Standard dealing with electro-magnetic emissions; and (e) an examination of the merits of the transfer of the responsibility for setting a new Australian standard for electro-magnetic emissions to the Australian Radiation Protection and Nuclear Safety Agency. 23. AMTA is the national industry body that represents the mobile telecommunications industry in Australia. 24. AMTA acknowledges that the deployment of telecommunications infrastructure and the exponential increase in mobile phone use has been accompanied by public debate about the possible adverse effects on human health. 25. AMTA considers the health of mobile phone users and the general public to be of utmost importance and as a result welcomes the opportunity to make a contribution to this Inquiry. 26. As part of its commitment to safety, AMTA monitors the progress of all known relevant scientific research activities on RF EME research. 27. AMTA has confidence about the safety of its members’ products and services. This confidence is based on a substantial body of scientific evidence and general consensus between the world’s leading scientific and health advisory bodies that there are no substantiated health effects associated with mobile telecommunications equipment operating within existing safety standards. Page 7 28. In assessing the overall scientific literature, studies are given different weigh, based upon a number of factors including consistency, independent replication of results and publication in peer reviewed scientific journals. 29. AMTA considers that access to reliable and accurate scientific information provides the essential platform for addressing existing electro-magnetic emissions related health and safety concerns. Through its monitoring of relevant scientific research activities both nationally and internationally, AMTA is able to contribute to the community’s understanding of these issues. The information gathered is made available widely throughout the general community in the form of brochures, information kits and web sites with relevant links. Page 8 Reference: (a) an examination of the allocation of funding from the Commonwealth's $4.5 million fund for electro-magnetic radiation research and public information; Key Points AMTA supports the continued funding of the NHMRC research program. This research will have greater value if it continues to be consistent with, and in support of, the global WHO and IARC assessments into the safety of EME. If additional high quality research is identified through the NHMRC, AMTA would support additional funding for research of those identified projects. AMTA also supports a Government sponsored, independent public information program, funded separately from the research program, to ensure that the community has access to reliable and accurate information about EME. 30. It is in the public and industry’s interest to ensure that there is an extensive research base upon which the safety of mobile telephones can be assessed. 31. AMTA supports continuing research into the possible health effects of EME. Consistent with this, AMTA supports the Commonwealth Government's $4.5 million funding program designed to support this research. 32. The Commonwealth Government should continue the research program currently being administered by the NHMRC. In light of the small population in Australia, and the significant amount of work currently underway internationally, the focus of further research should be consistent with, or complementary to, work currently underway internationally. 33. Australia is part of the large scale international research program being carried out in coordination with the WHO. This will include epidemiological (study of human populations), in vivo (animal) studies and to a lesser extent in vitro (biological cell) studies. This reflects the significance WHO attaches to each branch of inquiry in pursuing, and being able to better address, public health issues. 34. The NHMRC research program is financed by a levy on mobile carriers. To date, the allocations and areas of priority for research in the NHMRC program reflect international protocols for quality scientific research. Further, they reflect priority areas identified by the WHO1. 1 With regards to the allocation of the NHMRC funding program the Minister of health issued Press Releases on 14 July 1998 and September 1998 that outlined the following projects to be funded: $1.064 million to the University of Adelaide to expose genetically modified, cancer-prone mice to the electromagnetic fields emitted by mobile phones. This study is led by Page 9 35. The NHMRC studies reveal that a diversity of work is currently underway as a result of the funds. In particular, the studies all address areas in which there has been significant interest and debate, and therefore the findings of these studies will add to the overall knowledge base in this area while complementing overseas studies. 36. The NHMRC has recently called for further expressions of interest for funding to conduct research on possible biological effects of exposure to EME relevant to human health. 37. The NHMRC indicated in its advertisements that the research should be of national and international significance, and that the management of the research should be independent of the telecommunication industry. It was noted, however, that industry could be involved in providing specific technical expertise or equipment not otherwise available. AMTA supports the approach adopted by the NHMRC to industry involvement in research. 38. It is important that the measurement or calculation of RF dose (RF dosimetry) in these research studies is accurate so that the results are credible and can be incorporated into safety standards. This is an area where industry has unique experience and can provide the necessary equipment to ensure that the research program has adequate dosimetric controls. Industry welcomes involvement in the initial planning and setup of the experiments. 39. The funding mechanism used to raise the necessary funds has ensured that the industry fulfils its broader responsibilities in contributing towards the overall NHMRC program, while continuing to remain at arms length from the process of allocating the funding. Summary 40. Allocation of funds should continue to be administered independently by the NHMRC. If additional high quality research is identified through the NHMRC, AMTA would support additional funding for those identified projects. Professor Barrie Vernon-Roberts, Professor and Head of the Department of Pathology at the University of Adelaide and Director of the Institute of Medical and Veterinary Science. $90,000 to the NSW Cancer Council to conduct a 12 month pilot study of the use of mobile phones by people who have developed tumours in the brain, salivary glands or auditory nerve. The study will also compare people of the same age and sex who have not developed one of the indicated cancers. This study will be lead by Dr Bruce Armstrong. $50,000 to Swinburne University of Technology to conduct an 18 month study on human volunteers to determine if exposure to electromagnetic energy from mobile phones effects concentration, attention, problem solving and memory. This study will be led by Dr. Con Stough. $75,000 to Flinders University to examine the effect of radiofrequency electromagnetic energy exposure to DNA mutations and whether it may be regarded as a potential carcinogen. This study will be led by Professor Pamela Syke. Page 10 Reference: (b) a review of current Australian and international research into electro-magnetic radiation and its effects as it applies to telecommunications equipment, including but not limited to, mobile telephones; Key Point It is the assessment of the world's leading expert and health advisory bodies that there is no substantiated scientific evidence that using a mobile phone nor living near a mobile phone base station is harmful to human health. 41. AMTA has engaged Dr John Moulder, Professor of Radiation Oncology, Radiology and Pharmacology/Toxicology at the Medical College of Wisconsin, to undertake a review and analysis of the available scientific evidence relating to cancer for this Inquiry. A copy of AMTA’s electronic mail message to Dr Moulder is at Appendix H. 42. Dr. Moulder has taught, lectured and written on the biological effects of nonionizing radiation and electromagnetic fields for over two decades and is a recognised world expert in this field. Dr Moulder has agreed that he will submit a paper directly to the Senate Inquiry without prior reference to, or clearance from, AMTA. The Senate Inquiry Chair has been advised of this approach. 43. As outlined below, several national and international expert panels have recently evaluated the evidence on the potential health and biological effects of RF fields. These panels have consistently concluded that no public health risks have been demonstrated or indicated with respect to the use of wireless equipment such as mobile phones. 44. The only established mechanism for harm at mobile telephony frequencies is microwave heating. Tissue damage can result from sustained elevated tissue temperatures if the RF exposure is intense and prolonged. This mechanism is well understood and RF standards generally employ large safety factors to guard against any possibility of excessive exposure. For example, national and international safety standards and guidelines typically employ a safety factor of up to 50 (up to 50 times agreed safety level) for whole body and localised RF heating effects for the public. ICNIRP 45. The ICNIRP reviewed the evidence on potential health effects related to the use of mobile equipment in 1996 and again in 1998. ICNIRP concluded: (a) There is no substantive evidence that adverse health effects, including cancer, can occur in people exposed to levels at or below the ICNIRP limits for localized [Specific Absorption Rate] SAR set out in Page 11 this document (ICNIRP 1996, page 592) (b) Most of the established biological effects of exposure to RF fields are consistent with responses to induced heating resulting in rises in tissue or body temperature of greater than 1oC.(ICNIRP 1996, page 588) In contrast, non-thermal effects are not well established and currently do not form a scientifically acceptable basis for restricting human exposure for frequencies used by hand-held radio telephones and base stations. (ICNIRP 1996, page 591) (c) Epidemiological studies on exposed workers and the general public have shown no major health effects associated with typical exposure environments....This is consistent with the results of laboratory research on cellular and animal models, which have demonstrated neither teratogenic nor carcinogenic effects of exposure to athermal levels of high-frequency EMF. (ICNIRP 1998, pages 507-508) European Commission 46. The EC convened an expert group in 1996 to review the literature relating to possible health consequences of RF exposure from the use of mobile equipment (EC 1996). The European Commission's Expert Group concluded that: (a) Overall, the existing scientific literature encompassing toxicology, epidemiology and other data relevant to risk assessment, while providing useful information, provides no convincing evidence that radiotelephones [mobile phones] pose a long-term public health hazard. (page 23) (b) Therefore, it may be concluded that radiofrequency/microwave radiation is not a tumour initiator and that, if it is somehow related to carcinogenicity, this has to be by some other mechanism (e.g. by influencing tumour promotion). (page 35) (c) Overall, evidence for a co-carcinogenic effect of microwave radiation on tumour progression is not substantiated. (page 36) World Health Organisation 47. An international panel of experts convened for a seminar jointly sponsored by the WHO, ICNIRP, and the German and Austrian governments concluded that no known health hazards were associated with exposure to RF sources emitting fields too low to cause a significant temperature raise in tissue (Repacholi 1998, abstract). 48. The panel further concluded that although weak evidence exists, it fails to support an effect of RF exposure on mutagenesis or cancer initiation. There is scant evidence for a co-carcinogenic effect or an effect on tumour promotion or progression (Repacholi 1998, page 9). Page 12 Royal Society of Canada 49. The Royal Society of Canada, at the request of Health Canada, convened a panel of experts to undertake a comprehensive evaluation of the potential health effects of RF fields, which was published in 1999 (Royal Society of Canada 1999). (a) The panel found no evidence of documented health effects in animals or humans exposed to non-thermal levels of radiofrequency fields.(page 111) The panel recommended that no changes were needed in the existing Canadian exposure standards to protect against non-thermal effects of RF fields. (b) Scientific studies performed to date suggest that exposure to low intensity non-thermal RF fields do not impair the health of humans or animals. (page 3) (c) The weight of the evidence does not support the conclusion that exposure to RF fields of the type and intensity produced by mobile telecommunications devices contributes to the production or growth of tumours in animals or humans. (page 11) (d) The evidence suggested that RF fields may induce various biological effects, however such biological effects are not known to be associated with adverse health effects. UK House of Commons Select Committee 50. In 1999, the UK House of Commons Select Committee on Science and Technology (the House of Commons Report), considered the scientific evidence to date on the safety of mobile phones and base stations. While AMTA would not suggest that this was a scientific expert panel, they did take note of, and agreed with, the reports of the bodies listed above in the committee's own conclusions. Stewart Inquiry 51. In April 1999, the UK Government established an Independent Expert Group to rigorously assess the current state of research into the health impacts of mobile phones. 52. AMTA has welcomed the finding of the Independent Expert Group, known as the Stewart Inquiry, that mobile phones do not cause adverse health effects. 53. The Stewart Inquiry agreed with other expert bodies and health authorities around the world in concluding that the balance of evidence to date suggests that exposure to RF radiation below NRPB and ICNIRP guidelines does not cause adverse health effects to the general population [paragraph 1.17]. 54. Nevertheless, the Stewart Inquiry did report that despite public concern about the safety of mobile phones and base stations, rather little research specifically relevant Page 13 to these emissions has been published in the peer-reviewed scientific literature [paragraph 1.16]. The UK Government has not yet responded fully to the report of the Stewart Inquiry. Summary 55. AMTA accepts the advice of the world's leading expert and health advisory bodies that there is no substantiated scientific evidence that using a mobile phone nor living near a mobile phone base station is harmful to human health. Nevertheless, AMTA supports ongoing peer-reviewed scientific research into the possible health effects of mobile phones (refer Appendix G for list of references). Page 14 Reference: (c) an examination of the current Australian Interim Standard [AS/NZS 2772.1 (Int):1998], as it applies to telecommunications; Reference: (d) an examination of efforts to set an Australian Standard dealing with electro-magnetic emissions; Reference: (e) an examination of the merits of the transfer of the responsibility for setting a new Australian standard for electromagnetic emissions to the Australian Radiation Protection and Nuclear Safety Agency.2 Key Points Standards development in Australia should continue to be consultative, inclusive of all relevant expertise and consistent with international developments Appointments to standards development bodies or scientific advisory bodies should be made on the basis of relevant experience and expertise rather than on the basis of representation of interest groups With the absence of agreement on Standards Australia TE/7 Committee, the Government acted responsibly in seeking a new standard from ARPANSA and requesting a code from ACIF on the siting of infrastructure. The composition of the ARPANSA committee overseeing the development of the new Australian safety standard has appropriate participation and takes into account relevant expertise. 56. AMTA notes that the mobile phone industry complies with the standards contained in AS/NZS 2772.1 (Int):1998 and the more recent ACA EMR Regulatory Framework. 57. As a result of the Standards Australia Standards Setting Committee TE/7 not reaching agreement upon a new Australian Standard the Interim Standard (AS/NZS 2772.1 (Int):1998) was withdrawn. New Zealand was able to agree upon the provisions of the draft standard, and that has now been adopted in New Zealand. 2 As references (c), (d) and (e) all concern the standard setting process, AMTA has addressed these references together. Page 15 58. When the Interim Standard was withdrawn, the ACA implemented its own radiocommunications RF standard based on the Interim Standard. AMTA has supported the adoption of this approach in order to ensure that there is a regulatory standard in place for Australia. Towards A New Australian Standard 59. AMTA supports the harmonisation of standards at the international level. The WHO also supports the harmonisation of EME standards. The WHO commenced the standards harmonisation process in Zagreb in 1998, and believes that the International EMF Project may provide a useful framework for this work to be undertaken. The WHO has suggested that when it completes its EMF health risk assessments they could be applied to this framework, thereby assisting in the development of harmonised standards around the world. 60. Within Australia there has been a significant movement towards the adoption of international standards from a position previously favoring purely Australian standards particularly in such international industries as information technology (IT) and telecommunications. The Federal Government has strongly supported the adoption of international standards recognizing the increased commercial opportunities for industry by being able to supply to the global market. 3 61. From an industry's point of view, it is more efficient to provide consumers with safe and technologically advanced wireless communication devices if there is an opportunity, as now, to adopt the internationally accepted ICNIRP guidelines. 3 Rules have been established by the World Trade Organisation (WTO) to prevent product standards from acting as barriers to trade and are contained in the WTO Agreement on Technical Barriers to Trade (WTO Standards Agreement). All WTO members are obligated to comply with this agreement, and are subject to dispute settlement procedures for any failure to conform to its obligations. The WTO Standards Agreement applies both to government-mandated product standards (known as "technical regulations") and to voluntary product standards. It also prescribes rules governing procedures used to determine whether technical regulations or voluntary standards have been fulfilled. The basic requirements under Article 2 of the WTO Standards Agreement are that central governments (1) must not impose mandatory standards that discriminate against foreign products, and (2) must not impose mandatory standards that create unnecessary obstacles to international trade. To this end, technical regulations are not to be more trade-restrictive than necessary to fulfill a "legitimate objective" (such as national security or protection of human health or safety reflecting for example local environmental conditions). Article 2.4 of the WTO Standards Agreement specifically requires WTO members to use international standards whenever they are available in establishing technical regulations for particular products, unless the international standard is ineffective for a particular reason. The WTO rule mandates the use of international standards even if the international standards are not yet finalized but completion is "imminent,". Page 16 62. AMTA supports the need to develop a new Australian Standard based on the internationally accepted ICNIRP guidelines. The process for setting such a standard should be transparent, inclusive of all relevant expertise and, where possible, be consistent with international developments. In the context of the recently released report of the Stewart Inquiry4, AMTA notes that there are benefits in establishing standards that are fully consistent with the guidelines recommended by ICNIRP. 63. AMTA supports Australia's standard setting processes. These processes are consultative, involve all relevant expertise and are consensus based. 64. It was unfortunate that the draft Australian Standard could not be agreed upon within the Standards Australia consensus based process5. This is not to suggest that the process is flawed, but rather a recognition that, in this instance, there was not sufficient agreement to secure the new standard. 65. AMTA understands that amongst other technical issues a key point of disagreement related to how a cautionary approach could be incorporated into a technical science based standard. The WHO has warned that a precautionary policy for EMF should be introduced only with great care and deliberation (see Appendix E for full discussion). AMTA considers that the Precautionary Principle as defined by the WHO represents a sensible and scientifically based approach. 66. In order to introduce cautionary policies consistent with science-based standards, the ACA has requested that ARPANSA develop a technical standard for radiofrequency electromagnetic energy exposure and the Austaralian Communications Industry Forum (ACIF)6 develop a Code of Best Practice for Radiocommunications Infrastructure Deployment (ACIF Code). 67. The Terms of Reference for the proposed ACIF Code are: The Working Committee is to develop a Code of Practice regarding radiofrequency (RF) fields for the installation and operation of radiocommunications infrastructure that complements the technical standard for radiofrequency exposure limits. Best contemporary practices will be identified that are consistent with cost effective achievement of service objectives whilst keeping radiofrequency exposure to workers and the general public to the lowest practical level. Design, risk communication and mitigation, and operations will be addressed. 68. The ACIF Code will identify actions, behaviours and processes that reflect cautionary practices to be undertaken by providers when deploying telecommunications infrastructure . Because the ACIF Code will be a registrable The balance of evidence to date suggests that exposures to RF radiation below…ICNIRP guidelines do not cause adverse health effects to the general population (Stewart Inquiry 1.17) 5 Standards required 80% of votes cast in order to be adopted. 6 ACIF is an industry owned, resourced and operated company established by the telecommunications industry in 1997 to develop standards and codes to support competition and protect consumers. 4 Page 17 code, there will be a process to redress and/or heavily fine incidences of noncompliance. The code becomes mandatory once it has been registered by the ACA. 69. The ACIF Code is substantially advanced and following an extensive public consultation phase scheduled for later this year, the committee responsible for the development of the code is expected to report to the ACIF in December 2000. 70. AMTA supports the development of the technical science-based ARPANSA standard and the ACIF Code which provides a context for the application of a precautionary approach and more consultative approach to communities in the installation of radio transmitting equipment. Industry Participation 71. The issue of industry participation on standards setting and other expert panels is important. The suggestion is often made that industry should have no role in the development of standards for its own products. Such arguments ignore the fact that in many cases, including in the field of mobile telephony, there are few people with the required expertise outside of industry. A standards process that lacked the necessary expertise would be a flawed process. 72. The House of Commons report published in 1999 addressed the issue of whether industry representatives should be included on expert/advisory groups stating that it is vital that appointments to scientific advisory bodies are made on the basis of suitability and relevant expertise rather than on the basis of representation of interest groups. The Committee concluded: if industrial representatives have useful, relevant expertise, they should be included(page 32). Summary 73. In the absence of agreement within the TE/7 Committee, AMTA welcomes the action by Government to ensure that Australia does have an appropriate safety standard. The Australian Radiation Protection and Nuclear Safety Agency (ARPANSA)7 is an appropriate forum for the development of the new standard. 7 Chair: Dr Colin Roy, Director, NIR Branch, ARPANSA Members: Mr Vitas Anderson, Senior Research Engineer, EME, Safety Research Group, Telstra Dr Stan Barnett*, Project Leader, Bioeffects of Non Ionizing Radiation, CSIRO Division of Telecommunications,Industrial Physics Mr Wayne Cornelius, Head, EMR Section, NIR Branch, ARPANSA Dr Bruce Hocking, Consultant in Occupational Medicine Dr Ken Joyner, Director, EME Strategy & Regulatory Affairs, Motorola Australia Mr John Lincoln, Convenor, Electromagnetic Radiation Alliance of Australia Mr David McKenna, National Organiser, Community & Public Sector Union Dr Andrew Wood, Senior Lecturer in Biophysics, Swinburne University of Technology Ms Jill Wright, Senior Inspector, Division of Workplace Health & Safety, Qld Dept of Training & Industrial Relations Page 18 Consultants: Dr David Black, Occupational & Environmental, Physician Professor Mark Elwood, Director, National Cancer Control Initiative Secretariat: Mr Alan Melbourne, Manager, Standards Development Section, ARPANSA Mr Michael Bangay, Technical Officer, EMR Section, NIR Branch, ARPANSA Observers: Mr Ian McAlister, Manager, Radiocommunications Standards, Australian Communications Authority Dr Graeme Dickie, Radiation Health & Safety Advisory Council *Since resigned Page 19 Appendix A AMTA 74. AMTA is the national industry body that represents the mobile telecommunications industry in Australia. 75. AMTA’s membership includes telecommunications carriers, handset manufacturers, network suppliers, distributors, retailers and associated industries. Current members of the AMTA include: CARRIERS AAPT Wireless Pty Ltd Cable & Wireless Optus Limited Hutchison Telecommunication Iridium South Pacific One.Tel Ltd Primus Telecom Telstra Corporation Limited Vodafone Australia Leading Edge Telecoms Mobile Connection Mobile Network Mobiletronics Mobileworld Communications Solve Communications St Kilda Road Communications Strathfield Car Radios TechPacific Pty Ltd Vogue Communications EQUIPMENT SUPPLIERS Alcatel Australia Ericsson Australia Pty Ltd Fujitsu Australia Hyundai Electronics Australia Lucent Technologies Mitsubishi Electric Australia Pty Ltd Motorola Australia Pty Ltd NEC Australia Pty Ltd Nokia Mobile Phones (AUST) Pty Ltd Nortel Networks Australia Panasonic (Australia) Pty Ltd Philips Consumer Communications Qualcomm Incorporated RF Industries Pty Ltd Sagem Australasia Samsung Asia Scala Leathergoods Pty Ltd Siemens GEC Communications Sony (Australia) Pty Ltd DISTRIBUTORS/RETAILERS BDR Direct Communications Force Technologies Page 20 SERVICE PROVIDERS Pracom Limited RSL COM Australia Pty Ltd United Customer Management Solutions AFFILIATES ADI Limited AIC Worldwide ATUG Burson-Marsteller Centre for Telecommunications Information Networking Commercial Property Solutions Evernet Pty Ltd Market Faxts Middletons Moore & Bevins Red Rock Communications Pty Ltd Retaina Group TeleResources Pty Limited APPENDIX B How the mobile phone network operates 76. AMTA provides this information in recognition that there is often confusion about how the mobile phone network operates and in particular why mobile phone base stations are located in particular areas. 77. The mobile phone network operates with two interlinking elements being the handset and the base station. 78. The mobile phone handset operates by sending and receiving radio signals to and from antennas that are attached to radio transmitters and receivers, or base stations. The base station in turn links mobile phones with the rest of the mobile and fixed phone networks 79. Each base station provides radio coverage to a geographic area known as a cell. The pattern created by the coverage areas of the base stations looks similar to honeycomb cells and that is why the term Cellular Mobile Telephone Systems (CMTS) is used. 80. Most base stations are located at the intersection points of three cells. The size of these cells depends on three factors. The first factor is the local terrain as trees, hills and buildings can block radio signals. The second factor is the frequency band in which the network operates, as the higher the frequency - the smaller the cell. The third and final factor is the capacity, or the number of calls, needed in any given area. 81. Each cell is given a number of radio channels to communicate with mobile phone handsets. Within the Global system for Mobile Communications (GSM) network, there are 124 channels available, and in order to increase capacity, frequencies must be reused. One method of achieving this is to reduce the power level of the transmitters until there is minimal or no overlap of the coverage of the base stations between cells. Therefore the power levels of base stations are the lowest possible to ensure no interference with the adjoining cell. 82. As the demand for capacity increases, individual cells can be sub divided to provide for extra mobile phone users. This means more base stations (or antennas) which in general mean that they are operating at even less power which avoid interference. 83. One common misconception is that because there is a number of network operators, the industry is simply erecting more base stations. In fact, the mobile telecommunications industry will often co-locate with one another where it is technically feasible. In other cases, separate base stations will be required because capacity demands further division of cells. Commercial pressures dictate that the industry only erects sufficient base stations as the network requires or where coverage objectives need to be met. Page 21 84. With regards to the mobile phone handset, the mobile phone network via the base station controls the power output of the phone to a level that is sufficient to make and receive calls. This control of power is known as dynamic power control and it means that the phone is operating at the lowest level required to make and receive a call. . Under the GSM specification, the network is able to adjust the handset's output power in fourteen 2 decibel (dB) (ie a factor of 1.58) increments, giving a total of 30 dB (ie a factor of 1000) between the lowest and highest power outputs. Whether the lowest power rating would be achieved depends on the environment that the handset operates in. This power control is necessary to ensure that there is minimal or no interference with other cells, thereby allowing the frequencies in nearby (although not adjacent) cells to be reused. 85. The industry is very conscious that the building of base stations has an environmental impact. In order to reduce this impact, operators locate their base stations on existing structures wherever possible, like roof tops, water towers and radio communication mast structures. As already indicated, operators also seek to co-locate on base station towers if technically possible and finally, if there is no other technically feasible alternative, will seek to construct a new tower. 86. Network configuration is a highly technical and specific task. Base station location requires careful consideration. For the optimal operation of the network, which includes operating at the lowest power levels, base stations must be located within certain specific geographical areas. If the optimal network configuration is not permissible or possible there are several likely implications. Firstly, base stations will be forced to operate at higher powers levels to address the cellular design flaw, secondly, handsets will be required to operate at higher power levels to make and receive calls, and thirdly, users will experience greater call drop outs due to the gaps between cells. Page 22 APPENDIX C Economic and social benefits of mobile telephony Economic Benefits 87. Telecommunications is one of the world’s largest single industries, worth annually over US$500 billion. Moreover, telecommunications and related information technology products are the fastest growing group of products in world trade. 88. The telecommunications industry has become a booming sector of the Australian economy. Mobile telecommunications is leading that growth. 89. The growth has also been strong in the sectors which consume information technology inputs. For instance, between 1988-89 and 1996-97 the communications industries grew at nearly five times the rate of the overall Australian economy. During the same period, their workforce grew by 10% compared to an overall growth of the workforce of 7%. By 1996-97, 163,000 Australians worked in communications industries. 90. Industry revenues are estimated to grow to from A$23 billion in 1999/20008 to A$24.4 billion in 2000/2001. The mobile sector is estimated to grow from A$4.1 billion in 1999/2000 to A$4.7 billion in 2000/20019. In addition the carriers alone employ over 64,000 people throughout Australia. 10 91. The telecommunications industry has become a sizeable contributor to Federal Government Revenue. The Government has raised $12 billion from the initial Telstra float, $16 billion in the second tranche (with a valuation of $50 billion for the remainder). The Government has also received A$8.335 billion in dividends between 1990 and 1997 and has raised over $1.7 billion in spectrum auction proceeds since 1998. The Australian Government has included revenue of $2.6 billion for third generation spectrum sales in its 2000/2001 budget. 92. On the issue of tax, the listed carriers paid $1.861 billion in tax in 1999. In addition, the introduction of the Goods and Services Tax (GST) will mean that the industry will generate more tax revenue for the government. The exact impact of the GST is difficult to quantify, however, the current estimates are that telephone service prices will rise 7-8% as a consequence of the GST. This means the industry will be generating $1.7 billion in new tax with $312.8 million (based on 7% increase) coming from the mobile telephony sector. 93. In addition to the tax and license fees generated by the industry, the industry makes a significant capital contribution, which based on Telecommunications Carrier 8 Merrill Lynch Australasian Telecom Review, August 1999 p 88 ibid p88 10 Telecommunications Carrier Industry Development Plans: Progress Report 1998-1999 9 Page 23 Industry Development Plans, totaled $6 billion in 1998-1999 and $11.1 billion since 1 July 199711. 94. The economic success of the industry has not been lost on consumers either. In a paper prepared by Vodafone, and substantiated by KPMG, costs to consumers for mobile services, particularly for low volume users, has substantially fallen since 1993. This has occurred in association with a significant increase in the quality and the range of value added services that are provided as part of a standard mobile service. 95. The Vodafone report demonstrated that between 1993-1999, there was a 60% fall in the annual cost for the service and a 90% fall in the price of access and handset costs for a low volume Vodafone user. 96. The above figures clearly reveal that the telecommunications industry, and particularly the mobile sector is an enormous contributor to the Australian economy. It raises substantial revenues and taxes for the Government, employs significant numbers of Australians, make an enormous contribution to the development of Australian industry and all at the same time as having reduced costs to consumers. Social Benefits - Direct use in emergency situations 97. In considering the issues outlined in the Senate Inquiry Terms of Reference, AMTA believes that it is important to also take into account the enormous benefits of mobile telephony to the community since its inception a little over ten years ago. 98. When looking into the benefits of mobile telephony the first thing that becomes obvious is that there is very little research that has taken place to quantify the importance of mobile phones as personal safety devices. 99. In late 1997, AMTA commissioned Associate Professor Simon Chapman from the Department of Public Health and Community Medicine at the University of Sydney to undertake a study into the use of mobile phones in emergency situations12. The results, published in early 1998, demonstrated that mobile phones are playing an important role in many areas of the community. 100. Some of the key findings from the Chapman study were13 1 in 8 users have reported a road accident involving others; 1 in 16 users have reported a medical emergency (non road); 1 in 100 users have reported a psychiatric crisis; and 1 in 720 users have reported a heart attack 11 Ibid., p3 S.Chapman and W.N. Schofield, “Lifesavers and cellular samaritans: emergency use of cellular (mobile) phones in Australia” 31 January 1998 13 Ibid., p.8 12 Page 24 101. The report also found that 2 out of 3 users had used their mobile phone to call ahead and say they were running late, and that almost all of these had consequentially slowed or calmed down as a result. The authors concluded that the sheer number of mobile phones in the community may be causing an incalculable reduction in speedassociated motor vehicle accidents...14. This in itself shows that mobile phones have made an enormous contribution to community safety. 102. As impressive as the results were, the authors contended that the results were probably highly conservative estimates as the national extrapolations did not include multiple estimates of the total number of emergency use incidents. Therefore the research only indicated whether users had ever used their mobile phones in an emergency situation and not how many times they had utilised it. 103. The major daily newspapers have documented 18 incidents in the last 4 months where mobile phones have been used in emergency situations. For example, on 11 February 2000, the Brisbane Courier Mail reported that the Confederation of Bushwalking Clubs had listed mobile phones as an essential item to take hiking. Social Benefits - Mobile networks and DISPLAN 104. The mobile phone network plays an important role in disaster planning and has already proven its value in some of Australia's worst natural and man-made disasters. 105. In particular, the mobile phone industry has developed several types of portable base stations, which can be used in a variety of situations where additional coverage is needed due to the presence of large crowds or in emergency situations. 106. Portable base stations come in two forms. The first is referred to as a "Suitcase" and is made up of two subracks that can be installed in an existing exchange building where transmission, power and external plant has been made available. This type of setup is used when extra coverage or capacity is needed quickly and where it may be required to be in service for a reasonable period of time. 107. The other type of portable base station is of a type referred to as a "Quickcell" which is comprised of a trailer mounted RBS2000 system with self contained batteries, air conditioning and retractable mast to support GSM antennas. This unit can be set up and left on site for longer periods of time without staff being required to be in attendance. This unit is used for longer-term special events where new coverage or extra capacity is required and can also be quickly dispatched for DISPLAN requirements. 108. Typical uses of “Quickcell” are emergency and national disasters. In the Newcastle Earthquake, Thredbo and NSW Bushfire disasters, the portable base stations were used extensively to provide emergency services with a reliable communications network. These types of units can also be used for special events such as a Grand 14 Ibid., p11 Page 25 Prix or the like where there is a need for temporary additional coverage due to presence of large numbers of users. Social Benefits - Rural and regional users 109. The mobile phone is equally important to users living in rural and regional areas, but the traditional problem has been one of coverage. With the replacement of the analogue network with digital services, equivalent service has been provided to most areas to date, and will be complete when the last of the old analogue base stations are turned off. In addition, users across Australia, particularly those in remote areas, now have the option of satellite services which integrate with the GSM network where that is available. This ensures that most Australians, if not all, now have access to a mobile phone service whether by satellite or terrestrial network. 110. Unnecessary regulation that impedes the development of mobile networks may have the perverse consequence of blocking service in fringe areas. Under such circumstances safety benefits would be foregone for no proven health benefit. This is especially relevant in regional Australia where there might be serious consequences if a mobile phone could not be used in an emergency because of a service “blackspot”. Page 26 APPENDIX D The future of mobile telecommunications 111. The future of mobile telecommunications is positive with many new features and developments that will provide significant value and benefits to consumers. The impending introduction of third generation radio services will ultimately deliver voice, graphics, video and other broadband information direct to the user, regardless of location, network or terminal. The third generation services will also provide mobility on fixed and mobile networks, taking advantage of the convergence and synergies of existing and future mobile networks. 112. The key benefits of third generation include improvements in quality and security, incorporating broadband and networked multimedia services, flexibility in service and service availability. Moreover, third generation has reduced power requirements for handsets as well as smaller base station antennaes. 113. Third generation15 services will build on the existing capabilities of existing digital networks. Several Australian carriers having recently announced trials of General Packet Radio Service (GPRS), a transitional technology that offers greatly enhanced data capabilities. 114. Mobility will be built into many services that are currently regarded as stationary. Users will be able to make telephone calls to the office and be on the Internet simultaneously, or play interactive games, wherever they may be. 115. Internet and intranet access, video conferencing and interactive application sharing will become accessible. With the advent of packet switching mobile networks will even allow users of palmtop computers to remain constantly connected as data can be sent and received instantly. 116. From a service perspective third generation mobile technology will add two things. First, mobile services will be delivered with better performance and greater costeffectiveness. Second, third generation services will go on to facilitate new services with more comprehensive content. For instance, mobile multimedia messages will become more common thereby replacing traditional text-based emails. 117. Current mobile networks were originally designed for narrowband voice and data traffic. These networks will now evolve to wideband capabilities, allowing increased data rates for mobile multimedia and mobile internet-based services of the future. 118. The packet-switching core network will give users the feeling of being permanently connected to the services they are using, yet they will be charged on the basis of information sent and received, rather than on today's basis of connection duration. 15 Third generation mobile services are variously referred to as either IMT-2000, 3G or third generation services. Page 27 119. At the same time, completely new and innovative services that require high-speed data transmission will come to market. Australia is well placed to develop these new applications given its strengths in such areas as content delivery and application development. Provided that the spectrum is allocated in a timely manner and consistent with other developed economies, third generation could create a whole new industry for Australia. Page 28 APPENDIX E The precautionary principle and prudent avoidance 120. The twin track process of an ARPANSA EME Standard and an ACIF Code of Practice is appropriate as it separates the two disparate functions of these regulatory documents. This provides those charged with developing these documents with a much clearer definition of their purpose, which is to develop a credible science based EME Standard, and a Code of Practice that interprets the Standard in a social context that is relevant to radio transmitting equipment. 121. In March 2000, the WHO released a paper entitled “Electromagnetic Fields and Public Health Cautionary Policies”. On the issue of precautionary policies WHO acknowledged that throughout the world there has been a growing movement inside and outside of the government to adopt “precautionary approaches” for management of health risks in the face of scientific uncertainty. 122. WHO described three different policies concerning caution which have been developed to address concerns about public, occupational and environmental health issues in the face of scientific uncertainty. They are: The Precautionary Principle16 Prudent Avoidance17 ALARA (As Low As Reasonably Achievable)18 16 The Precautionary Principle is a risk management policy applied in circumstances with a high degree of scientific certainty, reflecting the need to take action for a potentially serious risk without awaiting the results of scientific research 17 Since 1989 Prudent Avoidance has evolved to mean taking simple, easily achievable, low cost measures to reduce EMF exposure, even in the absence of demonstrable risk. The terms “simple”, “easily achievable”, and “low cost”, however, lack precise meaning. Generally, government agencies have applied the policy only to new facilities, where minor modifications in design can reduce levels of public exposure. It has not been applied to require modification of existing facilities, which is generally very expensive. Defined in this way, Prudent Avoidance prescribes taking low-cost measures to reduce exposure, in the absence of any scientifically justifiable expectation that the measures would reduce risk. Such measures are generally framed in terms of voluntary recommendations rather than in terms of fixed limits or rules. 18 ALARA is an acronym for As Low As Reasonably Achievable. It is a policy used to minimize known risks, by keeping exposures as low as reasonably possible, taking into consideration costs, technology, benefits to public health and safety and other societal and economic concerns. ALARA today is mainly used in the context of ionizing radiation protection, where limits are not set on the basis of a threshold, but rather on the basis of “acceptable risk”. Under these circumstances, it is reasonable to minimize risk that can be presumed to exist even at levels below recommended limits, on the grounds that what constitutes "acceptable risk"can vary widely among individuals. ALARA has not been applied to setting public policy related to exposure to EMF. Indeed, it is not an appropriate policy for EMF (either powerline or Page 29 123. The WHO also cites the EC’s communication on the Precautionary Principle, released 2 February 2000. The EC communication details what measures need to be taken when applying the precautionary principle. Measures should be: a) tailored to the chosen level of protection; b) non-discriminatory in their application, i.e. they should treat comparable situations in a similar way; c) consistent with similar measures already taken, i.e. they should be comparable in scope and nature to measures already taken in equivalent areas in which all scientific data are available; d) based on an examination of the potential benefits and costs of action or lack of action (including, where appropriate and feasible, an economic cost/benefit analysis); e) provisional in nature, i.e. subject to review in the light of new scientific data; and f) capable of assigning responsibility for producing the scientific evidence necessary for a more comprehensive risk assessment. 124. The WHO makes it clear that the EC’s definition of Precautionary principle is “risk-oriented”, in that it requires an evaluation of risk research including cost-benefit considerations. It is clearly intended for use in drafting provisionary responses to potentially serious health threats, until adequate data are available for more scientifically based responses. 125. On the issue of Precautionary policies for EMF, WHO concludes: Prudent Avoidance and other cautionary policies regarding EMF exposure have gained popularity among many citizens, who feel that they offer extra protection against scientifically unproven risks. However, such approaches are very problematic in their application. The chief difficulty is the lack of clear evidence for hazard from chronic exposure to EMF below recommended guidelines, or any understanding of the nature of a hazard should one exist. While the weight of evidence needed to trigger a cautionary policy is undoubtedly lower than that needed to set exposure guidelines, clearly a hazard must be identified and some understanding is needed of the conditions under which it is likely to be present. 126. Another difficulty is the ubiquity of EMF exposure in modern society, at highly variable levels and over wide frequency ranges. It is therefore difficult to create cautionary policies that have consistency and equity. For example, typical urban environments contain a multitude of RF transmitters, ranging from low power communications transmitters to very high power broadcast transmitters. It is difficult to envision a consistent and equitable cautionary policy that would minimize RF radiofrequency fields) in the absence of any expectation of risk at low exposure levels and given the ubiquity of exposure. Page 30 EMF exposures from base stations given the presence of far higher powered sources in the same urban area. Indeed, attempts to implement a cautionary policy for cellular telephone masts have typically been done on a piecemeal basis, with no attention to other (much stronger) sources of RF energy in the environment. 127. In evaluating the implications for guideline limits, the WHO concludes: The above considerations suggest that a cautionary policy for EMF should be adopted only with great care and deliberation. The requirements for such a policy as outlined by the European Commission do not appear to be met in the case of either power or radio frequency EMF; however other related policies, such as Prudent Avoidance, may be justified. A principle requirement is that such policies, be adopted only under the condition that scientific assessments of risk and science-based exposure limits should not be undermined by the adoption of arbitrary cautionary approaches. That would occur, for example, if limit values were lowered to levels that bear no relationship to the established hazards or have inappropriate arbitrary adjustments to the limit values to account for the extent of scientific uncertainty. 128. The WHO’s warning in applying a cautionary policy for EMF “only with great care and deliberation” is also echoed by risk management theorists. Such theorists have found fault with the precautionary principle for failing to incorporate what is known in risk management literature as a “risk tradeoff analysis”. This analysis recognises that you need to consider not only potential risks of new technology, but also the risks in not pursuing the technology’s benefits. Risks have to be traded-off against each other to come up with sensible policy. 129. There have been numerous examples of the one-sided analysis coming from the prudent avoidance principle leading to catastrophic results. The Harvard Center for Risk Analysis book, “Risk versus Risk”, outlines many such cases (Harvard University Press, 1995). 130. One such case discussed in the book outlines how in Sri Lanka annual deaths from malaria returned to previous high levels five years after stopping DDT spraying. The number of annual malaria deaths had declined significantly while DDT was being used. 131. In conclusion, any risk reducing policy which limited the affordability of mobile phones or reduced the community’s access to mobile phone services would need to be considered along with the many lives saved each year by the technology. An unproven possible risk should not be traded off against a known public safety benefit. Page 31 APPENDIX F The use of handsfree kits 132. Portable handsfree kits are popular with mobile phone users. Their popularity is largely due to the flexibility that the kit provides for the user in that one hand is not required to be holding the phone at all times. The handsfree kits are also popular because in most States and Territories of Australia it is now illegal to drive while using a handheld mobile phone. The use of a personal handsfree kit can allow a person to drive and talk, although the industry encourages users to pull over to the side of the road if they need to make or receive a call. 133. In contrast to the report in the UK consumer magazine “Which?”, tests made by industry, independent laboratories and government agencies have all, without exception, shown that the absorption levels produced when using a handsfree kit (known as the Specific Absorption Rate or SAR) are significantly less than those produced without a handsfree kit. It should be emphasized, however, that mobile phones meet internationally recognised, science-based standards and guidelines for safe human exposure to EME with or without the use of handsfree kits. 134. Nevertheless, handsfree kits do provide a means for consumers who, notwithstanding the scientific evidence concerning the safety of mobile phones, continue to have personal concerns about EME. 135. The use of a handsfree kit should always be a matter of personal choice for consumers, except for in-vehicle use where road safety is a concern. Page 32 APPENDIX G References European Commission (EC) Expert Group, Possible Health Effects related to the Use of Radiotelephones. Proposals for a Research Programme by a European Commission Expert Group. (September 1996). International Commission on Non-Ionizing Radiation Protection (ICNIRP). Health Issues Related to the Use of Hand-Held Radiotelephones and Base Transmitters. Health Physics 70:587-593 (1996). International Commission on Non-Ionizing Radiation Protection (ICNIRP). Guidelines for Limiting Exposure to Time-Varying Electric, Magnetic and Electromagnetic Fields (up to 300 GHz). Health Physics 74:494-522 (1998). Repacholi MH. Low-Level Exposure to Radiofrequency Electromagnetic Fields: Health Effects and Research Needs. Bioelectromagnetics 19:1-19 (1998). Royal Society of Canada. A Review of the Potential Health Risks of Radiofrequency Fields from Wireless Telecommunication Devices (March 1999). Scientific Advisory System: Mobile Phones and Health, Science and Technology Committee, Third Report, Session 1998-99, UK House of Commons, HC 489-I (September 1999). Page 33 APPENDIX H Page 34