FOI-03727

Thank you for your request for information about the following:

##Request

<i>This is a formal request for information under the Freedom of Information Act 2000.
I am seeking full disclosure regarding the installation, governance, and health risk management of 5G telecommunications infrastructure located on or in close proximity to hospital premises.
 
This request is made in the context of your statutory duties under the Equality Act 2010, health and safety legislation, and wider public law obligations.
 
While the causation of symptoms attributed to electromagnetic exposure remains scientifically contested, the legal and policy position is materially broader and continues to evolve.
 
In particular:

* The Upper Tribunal decision in EAM v East Sussex County Council [2022] UKUT 193 (AAC) confirmed that Electromagnetic Hypersensitivity (EHS) is capable of constituting a disability under the Equality Act 2010 where it has a substantial and long-term adverse effect on normal day-to-day activities.<br>
* Case law concerning individuals with medical implants and electromagnetic exposure (including the “Thomas” case) has reinforced the principle that public bodies must consider electromagnetic environments where there is a foreseeable risk to health or functional impairment.

Planning and regulatory decisions are increasingly reflecting precautionary considerations, including:

* A Planning Inspectorate decision in Stroud where a telecommunications installation was refused, with health concerns forming part of the overall planning balance.<br>
* Local authority policy development, including Castleford/Wakefield Council’s amended local planning approach, which has taken community health concerns relating to 5G into account.<br>
* Brighton & Hove City Council ordered to pay costs after a 5G mast planning decision near a school was quashed at JR, where the Judge ruled the Council had failed to assess health impacts
 
Taken together, these demonstrate a clear trajectory in which health impacts, perceived or otherwise, and disability considerations are being treated as relevant by courts, tribunals, and public authorities, engaging duties under:

* The Equality Act 2010 (including reasonable adjustments and discrimination arising from disability)<br>
* The Public Sector Equality Duty (section 149)<br>
* Health and safety obligations to patients, staff, and visitors
 
In light of the above, I require full and transparent responses to the following:
 
1) Recognition of EHS within Legal and Policy Frameworks

* Please provide information to confirm whether the hospital has considered EHS within the framework of disability under the Equality Act 2010.<br>
* Please provide information on details of any policies, risk assessments, or equality impact assessments that address EHS or electromagnetic exposure.<br>
* Please provide information where if no such consideration has been undertaken, explain how the hospital is discharging its Public Sector Equality Duty in this context.
 
2) Equality Impact and Risk Assessments
 
Please provide information showing copies or summaries of any Equality Impact Assessments (EIAs) conducted in relation to the installation or operation of telecommunications infrastructure.

Please provide information confirming whether impacts on individuals who may be disabled due to electromagnetic sensitivity, or those with medical implants, have been assessed.
 
3) Recorded Complaints and Disability-Related Reports
 
Please provide information showing the number of complaints, incident reports, or occupational health referrals over the past five years relating to:

* Electromagnetic exposure<br>
* RF-EMF concerns<br>
* Symptoms consistent with EHS<br>
* Concerns relating to interference with medical implants

Please provide information showing anonymised summaries and any actions taken.
 
4) Monitoring and Compliance with Exposure Standards
 
Please provide information confirming whether the hospital undertakes EMF measurements in areas where telecommunications infrastructure is present.<br>
If so: 

* Provide frequency and highest recorded levels.

If not:

* Explain how compliance with guidelines set by the International Commission on Non-Ionizing Radiation Protection is verified.<br>
* Confirm whether independent monitoring will now be implemented.
 
5) Reasonable Adjustments and Safeguards
 
Please provide information confirming whether any reasonable adjustments have been considered or implemented for individuals reporting sensitivity to electromagnetic fields or those reliant on medical implants.
 
This includes (but is not limited to):

* Low-EMF areas<br>
* Shielding measures<br>
* Alternative working or treatment environments
 
6) Governance and Decision-Making
 
Please provide information identifying who holds responsibility for approving telecommunications installations on hospital premises.

Please provide information confirming whether health impacts, disability considerations, and relevant planning precedents are incorporated into the approval process.
 
7)  Insurance and Liability
 
Please provide information confirming whether the hospital holds insurance policies covering potential claims relating to electromagnetic exposure or interference with medical devices.

Please provide information confirming whether public liability insurance extends to disability-related claims arising from such exposure.
 
8) Awareness of Legal and Planning Developments
 
Please provide information confirming whether senior leadership, including the Chief Executive, is aware of:

* The Upper Tribunal decision referenced above<br>
* Case law relating to electromagnetic exposure and medical implants<br>
* Relevant Planning Inspectorate decisions and local authority refusals

Please provide information confirming what steps have been taken to ensure compliance with evolving legal and planning considerations.
 
9) Protection of Vulnerable and High-Risk Groups
 
Please provide information detailing what consideration has been given to vulnerable patient groups, including:

* Those with neurological conditions<br>
* Those with implanted medical devices<br>
* Individuals reporting environmental sensitivities

Please provide information confirming what mitigation strategies are in place.
 
10) Future Infrastructure Deployment
 
Please provide information confirming whether there are plans to expand or introduce additional telecommunications infrastructure.

Please provide information detailing what enhanced equality, health risk, and planning considerations will be applied prior to any such expansion.
 
Given the hospital’s duty of care and statutory obligations, and the emerging pattern of legal and planning recognition of health-related concerns in this area, this request is made in the public interest and requires a comprehensive response.
 
If any information is withheld, you are required to specify the exemption relied upon and provide justification in accordance with the Act.</i>

The NHS Business Services Authority (NHSBSA) received your request on 4 April 2026.

We have handled your request under the Freedom of Information Act 2000 (FOIA).  

##Our response

I am writing to advise you that following a search of our paper and electronic records, I have established that the information you requested is not held by the NHSBSA.

##Advice and assistance

Having reviewed your request, I believe that it is possible that Local councils or individual NHS Trusts may hold some or all of the information you require.

Please find the below website which holds a directory of all NHS Trusts.

https://www.england.nhs.uk/publication/nhs-provider-directory/ 

Organization: Freedom of Information Disclosure Log