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