{"id":278,"date":"2017-01-31T20:07:19","date_gmt":"2017-01-31T20:07:19","guid":{"rendered":"http:\/\/sagereports.com\/smart-meter-rf\/?p=278"},"modified":"2017-07-28T03:15:31","modified_gmt":"2017-07-28T03:15:31","slug":"susan-hackwood-phd-lora-lee-martin-director","status":"publish","type":"post","link":"http:\/\/sagereports.com\/smart-meter-rf\/?p=278","title":{"rendered":"Elihu Richter, MD, MPH <a href=\"http:\/\/sagereports.com\/smart-meter-rf\/docs\/letters\/Eli_Richter_CCST_-final.pdf\"><img src=\"http:\/\/sagereports.com\/smart-meter-rf\/docs\/pdf.png\"><\/a>"},"content":{"rendered":"<p style=\"text-align: center;\"><strong>Hebrew University-Hadassah<\/strong><\/p>\n<p style=\"text-align: center;\"><strong>School of Public Health and Community Medicine<\/strong><\/p>\n<p style=\"text-align: center;\">Unit of Occupational and Environmental Medicine<\/p>\n<p style=\"text-align: center;\"><span style=\"text-decoration: underline;\"><a href=\"http:\/\/www.md.huji.ac.il\/depts\/occenvmed\/\">http:\/\/www.md.huji.ac.il\/depts\/occenvmed\/<\/a><\/span><\/p>\n<p style=\"text-align: center;\"><em>contact information available only in attached download<\/em><\/p>\n<p style=\"text-align: right;\">26 January, 2011<\/p>\n<p>Susan Hackwood, PhD<\/p>\n<p>Executive Director<\/p>\n<p>California Council on Science and Technology<\/p>\n<p>Lora Lee Martin, Director<\/p>\n<p>Strategic Policy Initiatives and Government Affairs<\/p>\n<p>California Council on Science and Technology<\/p>\n<p><strong>Subject: <\/strong>Letter of Comment on Smart Meter Report<\/p>\n<p lang=\"en-GB\">\n<p>I have been invited by colleagues to submit my Commentary on CCST Report and Recommendations for Smart Meters using RF.  My comments are based on the information summarized in the Bioinitiative Report and the Seletun Reports, as well as the other reports in the recent scientific literature, The broader context for my commentary are the consequences of our past failures in  environmental epidemiology to heed  early warnings from other many population wide exposures in yesteryear, notably lead.<\/p>\n<p><strong>Personal Background<\/strong>: I am a medical epidemiologist who has assessed source-exposure-effect relationships for many chemical and physical agents over the past 40 years. This work has included work on lead, asbestos and smoking, pesticides, solvents, air pollution, and mixed exposures and ionizing radiation.  Since the late 1980\u2019s I served as Head of the Unit of Occupational and Environmental Medicine in Hebrew University-Hadassah School of Public Health and Community Medicine in Jerusalem Israel. I have also been involved in issues having to do with the medical ethics in public health, and served for several years as Chairman of the Ethics and Philosophy Committee of the International Society for Environmental Epidemiology and I am a member of the Collegium Ramazzini. I have published more than 100 scientific papers in the peer reviewed literature. Since the 1980&#8217;s, I have had the opportunity to assess the case for a cause effect relationship with many workers with past cancer and past severe exposures to RF\/MW, often after short latent periods. I have also supervised projects assessing community exposures to RF\/MW and ELF in Jerusalem. I have reported on cases of brain cancer in individuals with latency periods of less than 10 years and am currently writing an investigation of a cluster of cancer in workers with extremely high occupational exposures to RF.  I helped draft the Benevento and Seletun statements. In recent years, I have been particularly active assessing the use and scope of the Precautionary Principle in examining the anticipated risks from alternative technologies.<\/p>\n<ol>\n<li>Smart \tgrid networks, if using RF, will generate \t24\/7 round the clock ubiquitous involuntary indoor exposures to RF \u2013 \tin the everyday background environment of everyone in California in \thuman habitats. The background exposures produced by these grids \twill be substantially greater than those from point source WI-FI \trouters, microwave ovens and cell phones.  These whole body \texposures, though perhaps below levels of current regulatory \tstandards, (INCRIP-WHO, and IEEE), will exceed cumulative time \tweighted exposures producing the above outcomes, based on the \tliterature.<\/li>\n<li>Based \ton the evidence in peer reviewed \tstudies on the effects on these endpoints and the exposure \tprojections in Sage Associates\u2019 landmark report (see Sage, \t<span style=\"text-decoration: underline;\"><a href=\"http:\/\/sagereports.com\/smart-meter-rf\/docs\/Table7-8ElectricMeters_R1000_TA1-90Final.pdf\">http:\/\/sagereports.com\/smart-meter-rf\/docs\/Table7-8ElectricMeters_R1000_TA1-90Final.pdf<\/a><\/span> ) this project exposes large percentages of the general population \tto highly alarming involuntary exposure risk scenarios, taking into \taccount an array of modifying factors e.g. background exposures, \tdistance, reflection, and factors influencing access to exposure \tareas.<\/li>\n<li>Since \tthe publication of the Benevento Resolution and the BioInitiative \tReport, the body of evidence concerning health risks from exposures \tto RF continues to accumulate. In particular from cell phone use.  \tCell phone use involves the delivery of a high concentration of \tnon-ionizing radiation to the skull and brain for relatively brief \tperiods of time over a 24 hour period as  result of voluntary \tdecisions by users\u2014a situation far less aggressive to the general \tpopulation than involuntary exposure from the proposed Smart Meters. \t Models for predicting penetration into the whole body are now \tavailable, based on those developed by Gandhi and by Kuster. These \tmodels draw attention in particular to the risks from exposure to \tthe young.<\/li>\n<li>The \texposures from Smart \tMeters are the equivalent of exposure of the entire population\u2014the \tyoung, the old, the newborn, the unborn, and the sick, to \tenvironmental tobacco smoke, even if most members of the population \tdo not smoke.<\/li>\n<li>There \tis a huge body of evidence to refute the claim the so-called \u201chot \tmuffin theory\u201d that there are no effects from sub-thermal \texposures to NIR, and specifically RF\/MW (Benevento Statement,  \tBioInitative Report, London Report)  The effects pertain to ROS- \tReactive Oxygen Species, cellular changes, effects on DNA,  and \tneurobehavioral effects&#8211; e.g. deficits in memory, mood changes, \tfatigue, headache, as well as electro hypersensitivity and cancer, \tand effects on those with electronic medical implants.  It is \timportant to note that there are also concerns about the production \tof dirty electricity, itself a risk factor for many of these \toutcomes (Milham).<\/li>\n<li>Models \tof carcinogenicity or exposures to toxic and physical agents and \tcancer postulate that we cannot be certain there is a threshold \t(based on the DNA single hit model).  These models also postulate \troughly linear dose response relationships and recognize groups and \tage windows for special risks\u2014e.g. foetuses, newborns, persons who \tare immunocompromised and those with sensitivities on the basis of \tmechanisms which are still poorly understood. For populations, it is \tprobable that similar dose response models for exposure-risk \trelationships apply even though mechanisms involve resonance models \tof intensity and frequency.<\/li>\n<li>It \t  is fair to say that we are no longer talking about mere precaution \tof uncertain risk, but about prevention of highly probable and known \trisks. Based on the accumulating evidence, it is now fairly certain \tthat there will be widespread adverse public health impacts. What \tremains uncertain is how many will be affected, and whether there \tare time weighted intensity of exposure thresholds, below which \tthere will be absence of risk.<\/li>\n<li>The \tmost plausible scenario is that there will be &#8216;small&#8217; increases in \tindividual risk for the incidence of occurrence (e.g. cancer) or \tincidence and severity (e.g. neurobehavioral effects), applied to \tthe entire population from these networks\/ large population wide \tincreases in absolute numbers of people with adverse outcomes.  The \tepidemiologist Geoffrey Rose articulated the principle that  small \tincreases in so-called sub-threshold exposures result in  many  more \tindividuals with illness in the entire population than high \texposures delivered to small numbers of people. <em>This \tprinciple applies to the scenario of population-wide effects from \texposures to RF from networks of Smart Meters and concerns about \tdirty electricity<\/em>.<\/li>\n<li>Were \tthese population-wide exposures \tto smart meters to be part of a project carried out in a medical \tsetting, to test the risks and benefits of a new technology on human \thealth and well being, it would be rejected by a Medical \tInstitutional Review Board on ethical grounds as an unethical \texercise in human experimentation.<\/li>\n<li>The \trisks we are assessing today from exposure to RFMW and dirty \telectricity from Smart \tMeters placed everywhere recalls the story of population-wide \texposure to lead in gasoline \u2013 a subject concerning which I have \tmuch direct personal experience. In the 1970s, a mere 35 yrs ago, we \twere arguing as to whether or not an everyday blood lead level of \t30ug\/dl was a health risk. By 1979, that threshold dropped to \t20ug\/dl and thereafter through the 1980s to 10ug\/dl for children, \tand now we are not certain whether there is a threshold below which \tthere are no discernable adverse neurobehavioral effects, especially \tfor <em>in \tutero<\/em> and newborn exposures. We now know, in retrospect, that the entire \turban population, notably children, were receiving exposures which \twere impairing their IQ, emotional well being, and long term growth \tand development. These findings led to the elimination of lead from \tgasoline.  In retrospect, we were not heeding the early warnings \tregarding an impending population-wide hazard with disastrous \teffects. I suggest that in the case of population-wide exposure to \tRF, the situation is similar, with one exception: The warnings may \tno longer be early.<\/li>\n<li>Population-wide \texposure to man-made NIR represents a scenario relatively new in the \thistory of biology. It is difficult to assess risks from these new \texposures and their frequencies and wave patterns using experience \tbased on exposure to background naturally occurring NIR. Instead, we \tare required to rely on experimental studies and epidemiology of \texposure-effect relationships, using endpoints such as effects on \tstem cells, leaks from the blood brain barrier, as well \tneurological, cardiac and cancer endpoints. In addition, there are \tadditional vulnerabilities to the eyes and to the testes.<\/li>\n<li>I \twarn that we \tmay be on the cusp of a similar scenario here with regard to \tcommunity wide exposures to RF\/MW and dirty electricity from Smart \tMeters \u2014with one exception: there are safe alternatives.<\/li>\n<li>The \tPrecautionary \tPrinciple, in its various formulations, specifies that where there \tis uncertainty concerning the possibility of health risks from a new \ttechnology, the costs of doing nothing to prevent the exposure (e.g. \ta false negative) may be greater than a false positive (taking \tpreventive action). I add that in applying the Precautionary \tPrinciple, we are required to weigh the risks and benefits from 3 \toptions: doing nothing (i.e. no Smart Meters), and doing something \t(Smart Meters with RF) or a different kind of Meters using \tfiberoptics. We recognize that doing nothing carries itself certain \trisk having to do with the operations of the electrical ssgrid \tsystem.<\/li>\n<p><em><strong>But alternative technology- smart meters powered by fiber optics, which are without known risk<\/strong><\/em>, <em><strong>can be used to achieve the same objective. <\/strong><\/em><\/p>\n<li>There \tis no excuse for avoiding this investment with a permanent enduring \tprotection for the public in avoiding and not introducing fiber \toptics. For reasons just stated, it will be bad ethics and bad \ttechnology and, possibly wanton negligence, \trecklessness \tand incompetence to wilfully forego the last option.<\/li>\n<\/ol>\n<p lang=\"en-GB\">\n<p lang=\"en-GB\">I thank the Commission for the opportunity to submit my comments.<\/p>\n<p>Elihu D Richter MD, MPH (Assoc Professor)<\/p>\n<p lang=\"it-IT\">\n<p lang=\"it-IT\">\n<p lang=\"en-GB\">\n<p lang=\"en-GB\">References:<\/p>\n<p>1. BioInitiative Working Group, Cindy Sage and David O. Carpenter, Editors.  BioInitiative Report: A Rationale for a Biologically-based Public Exposure Standard for Electromagnetic Fields (ELF and RF).  <a href=\"http:\/\/www.bioinitiative.org\/\">www.bioinitiative.org<\/a>. August 31, 2007.<\/p>\n<p>2. Pathophysiology Journal, Special Issue 16: Volumes 1 and 2, 2009.  Elsevier Press.  <em>There are chapters on low-intensity radiofrequency and wireless radiation health effects based on scientific literature from the realms of genotoxicity, genomics and proteomics, neurology, blood-brain barrier effects, stress (heat shock) proteins, immunology and inflammatory diseases, cancer and public health consequences of ignoring warnings given global proliferation of wireless exposures at billions of times greater levels than earth and humans evolved with.<\/em><\/p>\n<p>3. WHO Research Agenda, 2010. WHO research agenda for radiofrequency fields, \u00a9 World Health Organization 2010<\/p>\n<p>4. REFLEX, 2004.  Risk Evaluation of Potential Environmental Hazards from Low Frequency Electromagnetic Field Exposure Using Sensitive <em>in vitro<\/em> Methods.<\/p>\n<p>5. Markova E, Malmgren LOG, Belyaev IY. 2009.\u00a0Microwaves from mobile phones inhibit 53PB1 focus formation in human stem cells stronger than in differentiated cells: Possible mechanistic link to cancer risk. \u00a0<em>Environmental Health Perspectives<\/em> On-line. 22 October 2009. doi:10.1289\/ehp.0900781<\/p>\n<p>6. <span style=\"text-decoration: underline;\">Belyaev IY<\/span>, <span style=\"text-decoration: underline;\">Markov\u00e0 E<\/span>, <span style=\"text-decoration: underline;\">Hillert L<\/span>, <span style=\"text-decoration: underline;\">Malmgren LO<\/span>, <span style=\"text-decoration: underline;\">Persson BR<\/span>. 2009. Microwaves from UMTS\/GSM mobile phones induce long-lasting inhibition of 53BP1\/gamma-H2AX DNA repair foci in human lymphocytes. <a><em>Bioelectromagnetics<\/em><\/a> 30: 129-141<\/p>\n<p>7. Sage C, Carpenter D.O.  2009. Public Health Implications of Wireless Technologies.  <em>Pathophysiology<\/em> 16: 233\u2013246.<\/p>\n<p>8. Capri M, Scarcella E, Fumelli C, Bianchi E, Salvioli S, Mesirca P, Agostini C, Antolini A, Schiavoni A, Castellani G, Bersani F, Franceschi C. 2004. In vitro exposure of human lymphocytes to 900 MHz CW and GSM modulated radiofrequency: studies of proliferation, apoptosis and mitochondrial membrane potential. <em>Radiation Research<\/em> 162: 211-218.<\/p>\n<p>9. Nittby H, Grafstrom G, Eberhardt JL, Malmgren L, Brun A, Persson BRR, Salford LG. 2008. Radiofrequency and Extremely Low-Frequency Electromagnetic Field Effects on the Blood-Brain Barrier. <em>Electromagnetic Biology and Medicine<\/em> 27:103\u2013126.<\/p>\n<p>10. Velizarov S, Raskmark P, Kwee S. 1999. The effects of radiofrequency fields on cell proliferation are non-thermal, <em>Bioelectrochem Bioenerg<\/em> 1999; 48: 177-180<\/p>\n<p>11. Wolke S, Neibig U, Elsner R, Gollnick F, Meyer R. 1996. Calcium homeostasis of isolated heart muscle cells exposed to pulsed high-frequency electromagnetic fields, <em>Bioelectromagnetics<\/em> 17:144-153<\/p>\n<p>12. Zwamborn APM, Vossen SHJA, van Leersum BJAM, Ouwens MA, M\u00e4kel WN. 2003. Effects of global communication system radio-frequency fields on well-being and cognitive functions of human subjects with and without subjective complaints, <em>TNO-report FEL-03-C148<\/em>; 148:1-89<\/p>\n<p>13.  Sage Associates, 2011. <em>Assessment of Radiofrequency Microwave Radiation Emissions from Smart Meters<\/em>. <span style=\"text-decoration: underline;\"><a href=\"http:\/\/sagereports.com\/smart-meter-rf\/\">http:\/\/sagereports.com\/smart-meter-rf\/<\/a><\/span><\/p>\n<p>14.  Grandjean P, Bellinger D, Bergman A, Cordier S, Davey-Smith G, Eskenazi B, Gee D, Gray K, Hanson M, van den Hazel P, Heindel JJ, Heinzow B, Hertz-Picciotto I, Hu H, Huang T, Jensen TK, Landrigan PJ, McMillen C, Murata K, Ritz Schoeters G, Skakkebaek NE, Skerfving S, Weihe P. 2007. The Faroes Statement: Human Health Effects of Developmental Exposure to Chemicals in Our Environment, Nordic Pharmacological Society. <em>Basic &amp; Clinical Pharmacology &amp; Toxicology<\/em> 102:73\u201375<\/p>\n","protected":false},"excerpt":{"rendered":"<p>Hebrew University-Hadassah School of Public Health and Community Medicine Unit of Occupational and Environmental Medicine http:\/\/www.md.huji.ac.il\/depts\/occenvmed\/ contact information available only in attached download 26 January, 2011 Susan Hackwood, PhD Executive Director California Council on Science and Technology Lora Lee Martin, Director Strategic Policy Initiatives and Government Affairs California Council on Science and Technology Subject: Letter [&hellip;]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[],"class_list":["post-278","post","type-post","status-publish","format-standard","hentry","category-uncategorized"],"_links":{"self":[{"href":"http:\/\/sagereports.com\/smart-meter-rf\/index.php?rest_route=\/wp\/v2\/posts\/278","targetHints":{"allow":["GET"]}}],"collection":[{"href":"http:\/\/sagereports.com\/smart-meter-rf\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"http:\/\/sagereports.com\/smart-meter-rf\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"http:\/\/sagereports.com\/smart-meter-rf\/index.php?rest_route=\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"http:\/\/sagereports.com\/smart-meter-rf\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=278"}],"version-history":[{"count":11,"href":"http:\/\/sagereports.com\/smart-meter-rf\/index.php?rest_route=\/wp\/v2\/posts\/278\/revisions"}],"predecessor-version":[{"id":499,"href":"http:\/\/sagereports.com\/smart-meter-rf\/index.php?rest_route=\/wp\/v2\/posts\/278\/revisions\/499"}],"wp:attachment":[{"href":"http:\/\/sagereports.com\/smart-meter-rf\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=278"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"http:\/\/sagereports.com\/smart-meter-rf\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=278"},{"taxonomy":"post_tag","embeddable":true,"href":"http:\/\/sagereports.com\/smart-meter-rf\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=278"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}