Public Consultation Template - ICNIRP Draft RF Guidelines, Appendix A, Appendix B
Comments to be uploaded until 9.10.2018
Dear Contributor,
Thank you for participating in the public consultation of the ICNIRP draft guidelines.
Please note that it is important that ICNIRP understands exactly the points that you are making. To facilitate our task and avoid misunderstandings, please:- be concise- be precise- provide supporting evidence (reference to publication, etc.) if available and helpful.
How to complete the comments table:
Please use 1 row per comment. If required, please add extra rows to the table.
This response document asks you to provide your ‘comment’, your ‘proposed change’, and the ‘context’ to this comment and proposed change. What ismeant by these is the following:
Comment : A brief statement describing the issue that you have identified (and that you would like ICNIRP to take into account in the final version ofthe guidelines).
Proposed Change: A brief statement describing how you would like the document changed to account for this issue.
Context: A brief statement identifying relevant documents in support of your comment and proposed change.
Please, provide your details below as per the online form and the provision of the privacy policy
Last name, first name: Hansson Mild, Kjell andHardell, Lennart

Email address:
kjell.hansson.mild@radfys.umu.se
lennart_hardell@hotmai.coml

Affiliation (if relevant): Dept Radiation Sciences,Umeå University, Sweden (Hansson Mild) and
The Environment and Cancer Research
Foundation, Örebro, Sweden (Hardell)If you are providing these comments officially on behalf of an organization/company, please name this here: organization/company☒ I hereby agree that, for the purpose of transparency, my identity (last and first names, affiliation and organization where relevant) will be displayedon the ICNIRP website after the consultation phase along with my comments.
☐ I want my comments to be displayed anonymously.

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Public Consultation Template - ICNIRP Draft RF Guidelines, Appendix A, Appendix B
Comments to be uploaded until 9.10.2018

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Document(Guidelines,App A,App B)

Line
Number#Type ofcomment(General/Technical/Editorial)

Appendix B330-406

GeneralComment. Proposed change. Context.

Surprisingly now in the background to the new ICNIRP guidelines they choose to ignore therecent IARC classification of RF exposure as class IIB , possibly carcinogenic to humans(IARC 2013). They now also disregard the latest animal studies (NTP, 2018; Falcioni et al,2018) on carcinogenesis. These have been discussed in a commentary by Melnick (2018) andclarified to that degree that they should have been considered in full.
After the IARC evaluation 2011 on RF exposure several other epidemiological studies havebeen published and they have been discussed by Miller et al (2018). In their conclusion they saythat the studies reported after the IARC evaluation are adequate to consider RF exposure as aclass IIA, probable human carcinogen. Together with the new animal findings they also argue
for an upgrade of IARC classification to class I, carcinogenic to humans.
Professor James C. Lin has recently made comments on the new animal experiments (2018) in apaper entitled “Clear evidence of Cell-Phone RF radiation Cancer Risk”. He ends his commentswith the “While complacencies abound for short-term exposure guidelines in terms of proving
safety protection, an outstanding question persists concerning the adequacy of these guidelines
for safe, long-term RF radiation at or below 1.6 or 2.0 W/kg. Perhaps the time has come to
judiciously reassess, revise, and update these guidelines.”
We agree fully with this statement by Professor Lin and urge ICNIRP to reassess and revise thesuggested guidelines in order to incorporate an adequate margin of safety also for long-term
exposure.
References
Falcioni L, Bua L, Tibaldi E, Lauriola M, De Angelis L, Gnudi F, Mandrioli D, Manservigi M,Manservisi F, Manzoli I, Menghetti I, Montella R, Panzacchi S, Sgargi D, Strollo V, Vornoli A,Belpoggi F. (2018). Report of final results regarding brain and heart tumors in Sprague-Dawley
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Public Consultation Template - ICNIRP Draft RF Guidelines, Appendix A, Appendix B
Comments to be uploaded until 9.10.2018
rats exposed from prenatal life until natural death to mobile phone radiofrequency field
representative of a 1.8 GHz GSM base station environmental emission. Environ Res.
Aug;165:496-503. doi: 10.1016/j.envres.2018.01.037. Epub 2018 Mar 7.
IARC Working Group on the Evaluation of Carcinogenic Risks to Humans. (2013). NonIonizing Radiation, Part 2: Radiofrequency Electromagnetic Fields, IARC Monographs on theEvaluation of Carcinogenic Risks Humans. [Online]. 102(2), pp. 1–460. Available:
https://monographs.iarc.fr/ ENG/Monographs/vol102/mono102.pdf
Lin JS. (2018). Clear evidence of cell-phone RF radiation cancer risk. IEEE microwave
magazine, Sept/Oct 2018, pp 16-24.
Melnick RL. (2018). Commentary on the utility of the National Toxicology Program study oncell phone radiofrequency radiation data for assessing human health risks despite unfoundedcriticisms aimed at minimizing the findings of adverse health effects. Environ Res. 2018 Sep
19;168:1-6. doi: 10.1016/j.envres.2018.09.010. [Epub ahead of print]
Miller AB, Morgan LL, Udasin I, Davis DL. (2018). Cancer epidemiology update, following
the 2011 IARC evaluation of radiofrequency electromagnetic fields (Monograph 102). EnvironRes. 2018 Jul 17. pii: S0013-9351(18)30347-5. doi: 10.1016/j.envres.2018.06.043. [Epub aheadof print]
National Toxicology Program. (2018, Mar.). Peer review of the draft NTP technical reports oncell phone radiofrequency radiation. [Online]. Available: https://ntp.niehs.nih.gov/events/past/index.html
Insert your proposed change.
Explain the context of your comment.

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Public Consultation Template - ICNIRP Draft RF Guidelines, Appendix A, Appendix B
Comments to be uploaded until 9.10.2018
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