07 May 2015

Submission of Comments on Final SCENIHR Opinion from the BioInitiative Working Group

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The BioInitiative Working Group submitted extensive comments to SCENHIR in spring of 2014 on their Draft Opinion on Potential Health Effects of Electromagnetic Fields (EMF) and provided detailed reasoning and evidence supporting the need for corrections in the Final Report.

+ BIWG SCENIHR Rebuttal to Opinion (DOWNLOAD PDF)

In January of 2015, SCENIHR (Scientific Committee on Emerging and Newly Identified Health Risks) issued a Final Opinion titled Potential health effects of exposure to electromagnetic fields (EMF), 27 January 2015. It ignores or dismisses the majority of comments provided. No substantive changes have been made by SCENIHR. The Final Opinion suffers from most of the same errors, omissions and wrong standard of evidence for determining whether and when a ‘potential health effect’ has been clearly established.

The Final Opinion (like the Preliminary Opinion) uses the wrong test by requiring absolute proof and mechanistic evidence of potential EMF effects. The charge to the Committee is explicit. It implies a precautionary assessment, not a proven risk. SCENIHR Committee’s name establishes that its purpose is to investigate emerging and newly identified health risks, not only those that are conclusively proven. Further, the title of the Opinion is Potential health effects of exposure to electromagnetic fields (EMF) clearly indicating it has reviewed the scientific literature to judge whether the potential exists. However, it fails to do this.

The issue is whether potential health effects have been identified and supported by some scientific studies, not whether these health effects and the mechanisms responsible for them have been proven beyond any shadow of doubt.

In order to provide decision-makers and the public an independent scientific assessment of the research on EMF, and whether the evidence is sufficient to make a finding that potential health effects are established, the BIWG has annotated the SCENIHR Final Opinion where appropriate. Original page numbers will be shifted as a result of adding new text comments, and highlighting in bold those Final Opinion study findings on which our conclusions are based.

The evidence here clearly and convincingly establishes the potential for health effects of exposure to electromagnetic fields (EMF). Based on the evidence provided in this Opinion, the Committee is obligated to draw to the attention of the Commission that EMF is a new and emerging problem which may pose an actual or potential threat.

Cindy Sage, MA
David O. Carpenter, MD
Editors, BioInitiative Reports