Rev Environ Health 2016; 31(4): 493–503

Open Access

Sarah J. Starkey*

Inaccurate official assessment of radiofrequency
safety by the Advisory Group on Non-ionising
Radiation
DOI 10.1515/reveh-2016-0060
Received September 30, 2016; accepted October 16, 2016

Abstract: The Advisory Group on Non-ionising Radiation(AGNIR) 2012 report forms the basis of official advice
on the safety of radiofrequency (RF) electromagnetic
fields in the United Kingdom and has been relied uponby health protection agencies around the world. This
review describes incorrect and misleading statementsfrom within the report, omissions and conflict of interest, which make it unsuitable for health risk assessment.
The executive summary and overall conclusions did notaccurately reflect the scientific evidence available. Independence is needed from the International Commission
on Non-Ionizing Radiation Protection (ICNIRP), the groupthat set the exposure guidelines being assessed. This conflict of interest critically needs to be addressed for theforthcoming World Health Organisation (WHO) Environmental Health Criteria Monograph on Radiofrequency
Fields. Decision makers, organisations and individuals
require accurate information about the safety of RF electromagnetic signals if they are to be able to fulfil theirsafeguarding responsibilities and protect those for whomthey have legal responsibility.
Keywords: AGNIR; brain; cognition; development; EEG;
electromagnetic; fertility; genotoxicity; health; ICNIRP;
immune; membranes; misleading; oxidative stress; proteins; Public Health England (PHE); symptoms; tumours;
wireless; WHO.

Introduction
The International Commission on Non-Ionizing Radiation
Protection (ICNIRP) set international exposure guidelines
for radiofrequency (RF) electromagnetic fields in 1998
*Corresponding author: Sarah J. Starkey, Independent Neuroscienceand Environmental Health Research, 27 Old Gloucester Street,
London WC1N 3AX, United Kingdom of Great Britain and Northern
Ireland, E-mail: sarahstarkey@tesco.net(1). Conclusions from subsequent ICNIRP reviews havesupported the guidelines. Within the United Kingdom(UK), Public Health England (PHE) commission scientificreviews by the Advisory Group on Non-ionising Radiation(AGNIR) to assess the safety of RF fields. AGNIR reviews,
along with PHE in-house assessments of exposures, form
the basis of PHE’s advice on the safety of RF signals. This
guides the UK government, organisations and decision
makers when assessing the safety of wireless devices andinfrastructure. The latest AGNIR review (2) has also beenrelied upon by health protection agencies around theworld, including the Australian Radiation Protection and
Nuclear Safety Agency (3) and Health Canada (4).
The majority of the global population absorb RF radiation on a daily basis from smartphones, tablet computers, body-worn devices, Wi-Fi and Bluetooth transmitters,
cordless phones, base stations, wireless utility meters
and other transmitters. For public health to be protected,
decisions need to be based on accurate information. The
AGNIR report is considered here for conflicts of interestand scientific accuracy.

Conflicts of interest
PHE stated, “The 2012 AGNIR report considered whether
there was evidence for health effects occurring in relation
to exposures below the ICNIRP levels” (5). At the time ofwriting the report, the chairman of AGNIR was also chairof the ICNIRP standing committee on epidemiology. Currently, six members of AGNIR and three members of PHEor its parent organisation, the Department of Health (DH),are or have been part of ICNIRP (Table 1). When the groupcharged with assessing whether there is evidence of healtheffects occurring at exposures below current ICNIRP values
have members who are responsible for setting the guidelines, it introduces a conflict of interest. How can AGNIR
report that the scientific literature contains evidence ofharmful effects below the current guidelines when severalof them are responsible for those guidelines? PHE provide©2016, Sarah J. Starkey, published by De Gruyter.
This work is licensed under the Creative Commons Attribution-NonCommercial-NoDerivatives 3.0 License.

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Starkey: Inaccurate official assessment of radiofrequency safety by AGNIR

the official advice on the safety of wireless signals within
the UK, but having members in ICNIRP introduces a conflict of interest which could prevent them from acknowledging adverse effects below ICNIRP guidelines.
PHE (the then Health Protection Agency) responded
to the report with “The Health Protection Agency welcomes
this comprehensive and critical review of scientific studies
prepared by the independent Advisory Group on Non-ionising Radiation” (6). The implication was that an independent group had produced the report and presented it to PHE.
However, at the time of writing, 43% of those in AGNIR werefrom PHE or the DH (2) (Table 1). PHE had misleadingly­welcomed the report which they were involved in preparing.

Scientific accuracy
The executive summary of the AGNIR report included“Taken together, these studies provide no evidence of healtheffects of RF field exposures below internationally accepted
guideline levels” [page 3 of the report (2)] and “the evidence considered overall has not demonstrated any adverse
health effects of RF field exposures below internationallyaccepted guideline levels” [page 4 (2)]. Accuracy is vital
when most people only read the executive summary andoverall conclusions from a 348-page report and national
and international public health decisions and exposures

are based on them. These conclusions did not accuratelyreflect the evidence, as described in e­ xamples below.
(a) Studies were omitted, included in other sections
but without any conclusions, or conclusions left out; (b)evidence was dismissed and ignored in conclusions; (c)there were incorrect statements. Terms such as ‘convincing’ or ‘consistent’ were used to imply that there was noevidence. Some examples fall into more than one category.
(a) Studies omitted, included in other sections but
without any conclusions, or conclusions left out
Only 7 studies were included in the section on reactive
oxygen species [ROS; page 94 (2); Figure 1]. These weresummarised by “production of reactive oxygen species(ROS) were increased in some studies, but not others”[page 106 (2)]. At least a further 30 studies relevant to
ROS or the possible resulting damaging state of oxidative
stress were included throughout the report, but with noreference to ROS or oxidative stress within the main text
for 16 of these (listed in Supplementary Information, SI)
and no mention of this subject in any other summaries
or conclusions. At least 40 studies were omitted (using
AGNIR restriction to the English language; identified from
PubMed and EMF-Portal databases or references within
the papers; SI). If these had been included, 79% of studies(61 out of 77) would have demonstrated evidence of significantly increased ROS or oxidative stress in response to

Table 1: AGNIR in 2012 and 2016 and membership of ICNIRP, PHE or DH.
AGNIR 2012
Swerdlow A.J. (Chair)
Conney S.W.
Coulton L.A.
Duck F.A.
Feychting M.
Haggard P.
Lomas D.J.
Noble D.
Mann S.M.
Maslanyj M.P.
Meara J.R.

AGNIR 2016
ICNIRP Chair of standing
committee on epidemiology
DH

ICNIRP

HPA
HPA
HPA

Peyman A.

HPA

Rubin G.J.
Sienkiewicz Z.J.

ICNIRP, HPA

Swerdlow A.J. (Chair)formerly ICNIRP

Conney S.W.
Coulton L.A.
Duck F.A.
Feychting M.
Haggard P.
Lomas D.

DH

Mann S.M.
Maslanyj M.P.
Meara J.R.
O’Hagan J.O.
Peyman A.
Powers H.
Rhodes L.
Rubin G.J.
Sienkiewicz Z.J.
Tedstone A.
Young A.

ICNIRP, PHE
PHE
PHE
ICNIRP, PHE
PHE

ICNIRP
Vice-Chair ICNIRPICNIRP, PHE
PHE

PHE was formerly known as the Health Protection Agency, HPA. PHE is part of the Department of Health, DH.

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Starkey: Inaccurate official assessment of radiofrequency safety by AGNIR

80

Number of studies

70
60
50
40
30
20
10
0
A

B

C

D

E

F

G

Figure 1: Comparison of the number of studies included in the
AGNIR report with those that could have been, for ROS, oxidative
stress or male fertility.
(A) studies included in the ROS section; (B) studies scatteredthroughout the report on ROS or oxidative stress (but with nosummary or conclusion); (C) studies which could have been included
for ROS or oxidative stress; (D) studies included on male fertility inthe cellular studies chapter; (E) studies included on male fertility
in animal studies; (F) studies included on male fertility in humans(in vivo); (G) studies which could have been included for male fertility. Dark shading indicates evidence of significant increase of ROS
or oxidative stress, adverse effect on male fertility or altered maletestosterone concentrations in response to a radiofrequency field;
light shading indicates no significant increase of ROS or oxidative
stress, adverse effect on male fertility or altered male testosterone
concentrations. Studies are listed in SI.

RF fields (Figure 1; SI). By only including a few of the available studies, not referring to many scattered throughout
the report and not mentioning ROS or oxidative stress inany conclusions or the executive summary, this importantarea of research was misrepresented. Oxidative stress is a
toxic state which can lead to cellular DNA, RNA, protein
or lipid damage (7, 8), is accepted as a major cause ofcancer (7), as well as being implicated in many reproductive, central nervous system, cardiovascular, immune andmetabolic disorders (7–14).
The conclusion for male fertility studies in animals
was “A substantial number of studies have investigatedthe effects of RF fields on testicular function, principallyin rats, and most report large, obvious effects. However,these results are largely uninterpretable due to inadequate
dosimetry or other shortcomings in the studies, and thus
are unsuitable for the purposes of health risk assessment.
One well-conducted study reported no effects on testicular function in rats exposed to 848 MHz CDMA signals”[page 191 (2)]. For male fertility in humans (in vivo), it
was concluded, “The evidence on the effect of RF fields
on sperm quality is still weak and the addition of the two
new studies does not allow reliable evaluation of the presence or absence of a health effect. Some suggestive positive results, although not convincing, give justification for

495

further studies with improved methods. The evidence on
effects on male subfertility is very limited, and allows noconclusions”.
At least 22 studies on male fertility were omitted(AGNIR restriction to the English language; identified
from PubMed or EMF-Portal databases or references
within the papers; listed in SI). Considering those identified as included throughout the report (excluding threesubsequently retracted, SI), 78% of studies (18 out of23) described significant adverse effects on sperm, male
reproductive organs or changes in male testosterone concentrations (SI). If the 22 references identified as omitted
had also been included, this would have been 35 out of 45,
78% (Figure 1; SI). Isolating small samples of evidence inchapters on cells, animals or humans (Figure 1) may havemade it easier to dismiss significant effects on male reproductive health. Inaccurately, in the overall and executive
summaries, the evidence for adverse effects on male fertility disappeared: “Despite many studies investigating
effects on male fertility, there is no convincing evidence
that low level exposure results in any adverse outcomes on
testicular function” [page 192 (2)] and for humans, in vivo,“The limited available data on other non-cancer outcomes
show no effects of RF field exposure” [page 4 (2)]. The term
‘convincing’ is subjective and can erroneously imply that
there is no evidence. The human data on male fertility did
not show “no effects of RF field exposure”.
Some studies, mostly those which had tested signals
from real mobile devices, were dismissed as uninterpretable because they had not described the dosimetry, theprocess of determining internal electromagnetic quantities relating to exposure in tissues, in enough detail.
Limited descriptions restrict possible interpretations,but do not make them uninterpretable. If the questionis ‘do mobile phone signals damage male fertility?’, realphone signals are highly relevant because they allow possible effects of the complex patterns of fields to whichhumans are exposed to be investigated. ICNIRP only
accept thermal effects of RF fields and focus on averageenergy absorbed. Highly controlled, simulated signals
with descriptions of overall specific absorption rates(SARs) are suited to the assessment of temperature rises
in cells or tissues. Real signals make it more difficult tomeasure average energy, but have characteristics which
controlled, simulated signals lack. The complex field
patterns, with variable peak field strengths and intervals
between transmissions, may influence biology in waysthat controlled, simulated patterns cannot, but they are
not represented by time-averaged, duty factor reductionsof described energy absorption. Responses to RF fields
can be greater for intermittent exposures than continuous
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496

Starkey: Inaccurate official assessment of radiofrequency safety by AGNIR(15, 16) and depend upon the pulse characteristics for thesame average power (17). Effects can be dependent on frequency, modulation, signal strength (intensity windows),
durations of exposure and polarisation (18, 19). For the
nervous system, complex signals from real devices may
modulate neuronal activity, similar to endogenous electricfield ephaptic (non-synaptic) coupling in the brain (20).
There is evidence that endogenous electric fields feedback
to modulate neuronal activity (21). Fields with amplitudes
similar to those found in vivo, applied to neocortical brainslices, modulated and entrained neuronal spiking activity(21). Irregular patterns of fields with complex dynamics,
which mimicked in vivo fluctuations, entrained neuronal
activity more strongly than sine waves (21). There are valid
reasons for testing the effects of signals from real mobile
devices, and dismissing these limited and misrepresented
the evidence.
The summary for neurocognitive effects in humans
stated, “Studies of cognitive function and human performance do not suggest acute effects of exposure to RF fields
from mobile phones and base stations” [page 226 (2)]. But
acute detrimental effects on cognition were omitted fromthe report (22–25) or mentioned in different sections (26–29). Increased errors during a memory task (26), slowed
performance (27) or decreased accuracy in a cognitive test(28) were reported in the electroencephalogram (EEG)
section [pages 209–213 (2)]; slowed performance in cognitive tests (29) were reported under sleep [page 215 (2)].
Omitting the studies which found effects in the relevant
section led to an incorrect conclusion.
For symptoms in humans, “Sufferers differ in termsof the type of symptoms that they report, the speed withwhich symptoms develop and the types of ­electromagnetic
field that appear to be problematic” [page 232 (2)]. Acuteprovocation studies in humans expose all subjects to thesame short electromagnetic signal to see whether they
all respond with the same immediate symptoms. If the
speed with which symptoms develop and types of trigger
differ between individuals, then in a group overall a lackof significance might be expected for identical acuteprovocations, but this does not mean that some individuals cannot respond to certain fields given adequate
exposure durations, intervals between ­provocations
and low background electromagnetic fields, as has beenreported (30, 31). The executive summary concluded,“The evidence suggests that RF field exposures below
guideline levels do not cause acute symptoms in humans”[page 3 (2)], without explaining limitations.
Many of the longer-term observational studies
described significant associations of RF exposures withsymptoms, albeit with limitations in study designs: “Whilesome, though by no means all, of the studies reviewed
above appear to suggest an association between mobile
phone use and symptoms…” [page 245 (2)], followed by“almost all of the studies share a fundamental methodological problem which makes it difficult to draw any firm
conclusions from them: these studies relied upon the participants’ own descriptions of their mobile phone usage as the
exposure variable for their analysis and on self-descriptionof symptoms while knowing exposure status” (2). Longerterm studies on symptoms were omitted from the executive summary.
No mention was made of the World Health Organization (WHO) International Agency for Research on Cancer(IARC) classification of RF fields as a possible humancarcinogen in 2011, which was based on limited evidence
supporting carcinogenicity below ICNIRP guideline
values (32).
(b) Evidence dismissed and ignored in conclusions
For in vitro membrane effects, the report showed that all
studies included (seventeen (33–49); non-blood-brain
barrier (BBB)) described significant responses to RF signals
except for one, which had tested extremely high powers,
far greater than ICNIRP guidelines, that heated the tissue[250–3600 W/kg time-averaged SAR (50); pages 102 and103 (2)]. This heating study had reported an effect, an invitro recoverable decrease in population spike amplitudein the hippocampus in response to the RF signal, but noeffect on long-term potentiation (50). The report text alsomentioned that Falzone et al. had found no changes to thecell membrane [(51), page 101 (2)], but they had measured
markers of apoptosis, programmed cell death, not direct
effects on membranes; this paper was not included in
the table of studies on membrane effects. The membrane
studies were weakly dismissed: “In general, most studies
report finding effects on cell membranes when exposures
are made at mobile phone frequencies. However, the effects
reported are varied and, although the majority find effects,
neither is this unanimous nor does it necessarily provide
supporting evidence of a consistent effect. The variety ofcellular systems and exposures makes comparisons of theeffects on the cell membrane problematic and without independent replication it is difficult to assess the robustness
or even the validity of the findings.” Studies had looked
at a range of effects and all, below high power heating,reported significant changes, strengthening the validity of
the findings.
For direct effects on proteins, 15 out of 16 studies
listed found significant effects of RF fields [pages 103–105(2); (52–67) effect; (53) no effect]. The conclusion was “Ingeneral, most of the studies that have investigated changes
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Starkey: Inaccurate official assessment of radiofrequency safety by AGNIRin protein function or structure due to exposure to RF fields
have found effects. However, at the present time the effects
have not been demonstrated to be robust by independent
replication; so although the concept of a direct effect of RF
field exposure on protein structure is interesting, further
research is needed to establish if this is a real phenomenon.” Ninety-four percent of the studies listed on direct
effects on proteins, from 14 different groups, found significant effects, but the conclusion was turned around to
imply that these may not be real.
“Where replications have been undertaken they do notsupport the original findings. This continued lack of robust
evidence makes the possibility of an effect of RF fields oncells more unlikely” [page 105 (2)]. An effect on cells is notunlikely when there were significant effects in all of therelevant studies on membranes (excluding BBB), all of thestudies except one on direct protein effects, the majorityof the studies on oxidative stress or male fertility, all of the
included in vitro genotoxicity studies on epithelial cells[see c; page 84 (2)] and 47% of in vitro genotoxicity studies
which could have been included in the report (see c; SI).
“Studies on cell membranes and direct effects on proteins mostly found effects of RF field exposure. However, noconclusions can be made as there are no common patternsof exposure conditions or types of effects caused by the
exposure” [page 106 (2)]. Out of 33 studies on direct effects
on proteins or cell membranes, 32 described significant
effects of RF signals below high power heating, but thesedisappeared in the conclusions.
By the end of the report, the conclusion on cellularstudies had incorrectly become “There are now several
hundred studies in the published literature that have lookedfor effects on isolated cells or their components when
exposed to RF fields. None has provided robust evidence for
an effect” [page 318 (2)].
A summary for human brain EEG recordings stated,“the EEG studies published since 2003 do provide someevidence that RF fields could influence brain function, andthis should remain an area of interest” [page 226 (2)]. ManyEEG studies (awake or asleep subjects) reported changes
in electrical field potential oscillations, evoked responses
or interhemispheric coupling, but these were dismissed:“it remains unclear whether these RF effects, if they exist,
are material to human health or not”. Electrical fieldpotential oscillations can synchronise activity of local
networks (21) or propagate signals over large regions, controlling brain developmental processes, including neurogenesis, apoptosis, neuronal migration, differentiationand network formation (68). Oscillations have been linked
with active processing or inhibition of cognitive functions(69) and cyclic modulations of neuronal excitability (21).

497

References available at the time of the report describing
behavioural problems (70–72) and changed psychomotor
performance (73) associated with pre-natal or childhood
RF exposures, cell death and reduced cell numbers in thebrain (74–83) and cognitive inhibition (22–29, 78, 79, 84–88) supported the possibility that RF-induced changes inelectrical activity could contribute to altered brain development or cognition.
The executive summary included “There has been no
consistent evidence of effects on the brain, nervous systemor the blood-brain barrier, on auditory function, or on fertility and reproduction” [page 3 (2)]. The term ‘consistent’dismissed areas for which the majority of studies had
found adverse effects, such as male fertility. Of the studies
included in the report on pregnancy and development,
which quantified effects of pre-natal or early neonatal RF
exposures on neuronal cell numbers in the developing
brain [pages 184–187 (2)], four found significant decreases:
pyramidal cells in the rat hippocampus (74), granule cells
in the rat dentate gyrus (75), Purkinje cells in the mouse
cerebellum (76) and a transient increase in neurogenesisof the subventricular zone following 8 h of RF exposure
over 2 days, but a long-lasting decrease in neurogenesis
following a 24 h exposure over 3 days (77), measured fromproliferating cells in the rat rostral migratory stream. One
study described no effect on neuronal numbers in themouse hippocampus (89). Whilst not all reported effects,
the studies supported RF exposures decreasing neuronalnumbers in the brain during pre-natal and early neonatal
development at least in some circumstances (74–77). The
executive summary misleadingly implied that because not
all studies reported the same effects, RF signals have noeffect.
The AGNIR report suggested that symptoms inhumans may be caused by people’s perception of being
exposed, rather than the actual electromagnetic fields[page 246 (2)]. Imagining a signal to be present is unlikely
to explain all responses, particularly symptoms reported
in response to RF signals under blind or double-blindconditions (30, 31, 90). Many other studies support biological responses being related to the electromagnetic
signal, including evidence from cultured cells, in vitro
preparations, animals, plants or asleep humans, noneof which reacted with significant changes because they
imagined that RF signals were present. That living things
can respond to low power RF signals is now supported bya large body of research.
(c) Incorrect statements
For child development [page 260 (2)], maternal mobile
phone use during pregnancy was associated with
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Starkey: Inaccurate official assessment of radiofrequency safety by AGNIR

behavioural problems in children at the age of 7 (70, 71)
and lower psychomotor performance was described forchildren of mothers who had the highest mobile phone
use during pregnancy (73). The report said, “these results
are only suggestive of an effect, rather than being conclusive evidence of one”. Increased conduct problems werereported in 8–17-year-olds with the highest quartile of
RF exposures (72) [page 250 (2)]. As studies suggested
an effect on child development, the executive summary
incorrectly stated, “data on other non-cancer outcomes
show no effects of RF field exposure” [page 4 (2)].
For risks of brain tumours or acoustic neuromas inhumans, “the similar results of all investigators except
the Hardell group, with no methodological inferiorities
in these other investigators’ studies overall, suggest thatthe results of the Hardell group are the problematic ones”[page 308 (2)]. However, some significantly increased
risks of brain tumours or acoustic neuromas were
described in Hardell and non-Hardell studies [pages
282–306 (2), (91)], although non-Hardell significant data
were omitted from the data tables and only mentioned
in the text. For example, for gliomas with an ipsilateralmobile phone use of ≥ 1640 cumulative hours (ages
30–59), the international Interphone study reported
a significant odds ratio (95% confidence interval) of
1.96 (1.22–3.16) and Hardell et al. reported a significant
odds ratio of 2.32 (1.14–4.73) (91). Had the data tables
included results for ipsilateral exposures, duration ofuse and more detail of the pooled Interphone studies,
it would have been clearer that significantly increased
risks had been reported. “With no methodological inferiorities in these other investigators’ studies” was incorrect. The Interphone study did not take cordless phone
use into account in the analysis for mobile phones (91);the Danish cohort study misclassified corporate mobile
phone users as non-users, as well as those who took
subscriptions out after 1995 (92).
The comment in the executive summary, “the accumulating evidence on cancer risks, notably in relation tomobile phone use, is not definitive, but overall is increasingly in the direction of no material effect of exposure”[page 4 (2)], was misleading. Significant risks were mostcommon for ipsilateral exposures, latencies of 10 years
or more since first use or the highest cumulative hoursof use (2), (91). If anything, as use increased, the evidence increasingly pointed towards possible risks.
The executive summary stated for cells in vitro: “Inparticular, there has been no convincing evidence that RF
fields cause genetic damage or increase the likelihood ofcells becoming malignant” [page 3 (2)] and in the chapter
on cellular studies: “Results from studies using other cell

types are also contradictory. Epithelial cells exposed to …”[page 86 (2)]. However, all in vitro studies included onepithelial cells [four, one retracted, page 84 (2), (93–95)],
from more than one laboratory, found damage to DNA or
chromosomal aberrations in response to RF signals. Fortysix percent of genotoxicity studies identified as includedin the report (36 out of 78; SI) described evidence for genotoxicity in response to RF fields, but at least 40 genotoxicity studies were omitted (SI). If these had been included,
52% (61 out of 118) of genotoxicity studies overall and 47%
of in vitro (36 out of 76) would have described evidence
for genotoxicity (SI; AGNIR restriction to the English
language; identified from PubMed and EMF-Portal databases). AGNIR found the genotoxicity evidence unconvincing, but a more accurate conclusion could have beenthat RF signals appear to be genotoxic under certain circumstances, but not others.
For the immune system [page 174 (2)], a Russian
study was included (96), which mostly replicatedearlier Russian studies and a French one which did not(97). The conclusion was “it is clear that the results of
the original Soviet studies have not been confirmed”. It
was not clear, as the report also referred to the Russian
study with “These results do not appear to be identicalto the original, although they do show the same tendency.
Results of ELISA reinforced this conclusion. Grigoriev andcolleagues also reported that very few pregnant animals
receiving serum from exposed animals gave birth to live
animals (4 out of 12), which is also supportive of the previous results”.
The report described cognitive performance of RFexposed and sham-exposed Alzheimer’s disease-like
transgenic mice (98) [pages 144–147 (2)]. However, there
were no shams in the study, as controls were housed in a
separate room without a Faraday cage; exposed mice (two1 h exposures per day, 918 MHz, SAR 0.25 W/kg) were continuously housed within a Faraday cage for up to 9 months(98). Cognitive improvements in the exposed groups compared to controls may have been the result of long-term
protection from environmental electromagnetic fields by
the Faraday cage. Because background man-made electromagnetic fields may alter experimental results and areoften present in experimental environments, they ought
to be described in the Methods section for all biologicalstudies, but are often omitted, as in this paper. The AGNIR
report conclusions [page 318 (2)] described this as a wellperformed study, whilst other effects of RF signals on cognition were dismissed as inconsistent. Varied responses
might indicate dependency upon physiological or experimental conditions and do not automatically justify ignoring evidence.
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Starkey: Inaccurate official assessment of radiofrequency safety by AGNIR

Conclusions
Decisions about involuntary, continuous and widespreadRF exposures in schools, hospitals, workplaces and public
and private spaces in the UK and around the world havebeen made based upon inaccurate conclusions of the
AGNIR report. Published in 2012, it continues to be used
to justify RF exposures and dismiss concerns about possible adverse effects on health, well-being or development.
The denial of the existence of adverse effects of RF
fields below ICNIRP guidelines in the AGNIR report conclusions is not supported by the scientific evidence.
Studies have, as described as examples in this review,
reported damage to male reproductive health, proteinsand cellular membranes, increased oxidative stress, cell
death and genotoxicity, altered electrical brain activity
and cognition, increased behavioural problems in children and risks of some cancers. For future official RF
reports, it is important to check that conclusions accurately reflect available evidence before decisions which
impact on public health are made based on the executive
summary and overall conclusions.
The involvement of ICNIRP scientists in the misleading report calls into question the basis and validity of
the international exposure guidelines. To protect publichealth, we need accurate official assessments of whether
there are adverse effects of RF signals below current international ICNIRP guidelines, independent of the group
who set the guidelines.
The anticipated WHO Environmental Health Criteria Monograph on Radiofrequency Fields, due in 2017, isbeing prepared by a core group and additional experts(99), with 50% of those named, being, or having been,
members of AGNIR or ICNIRP (Table 2). Considering theimportance of the Monograph for worldwide public healthand the inaccuracies described here, independence fromAGNIR would increase confidence in the report findings.
Independence from ICNIRP is necessary to remove theconflict of interest when effects below ICNIRP exposure
guidelines are being assessed.
Schools, hospitals, employers, organisations andindividuals have legal responsibilities to safeguard thehealth, safety, well-being and development of children,
employees and members of the public. But they are unable
to fulfil their legal responsibilities when they have been
provided with inaccurate information and the evidence ofpossible harm has been covered up.
Individuals and organisations who/that have madedecisions about the often compulsory exposures of others
to wireless RF communication signals may be unaware of
the physical harm that they may have caused, and may

499

Table 2: Named contributors to the WHO Environmental HealthCriteria Monograph on Radiofrequency Fields [(99), in preparation]and membership of ICNIRP or AGNIR.
Core group
Feychting M.
Mann S.M.
Oftedal G.
van Rongen E.
Scarfi M.R.
Zmirou D.
Additional experts
Aicardi G.
Challis L.
Curcio G.
Hug K.
Juutilainen J.
Lagorio S.
Loughran S.
Marino C.
McNamee J.
Naarala J.
Peyman A.
Röösli M.
Rubin G.J.
Schoemaker M.
Selmaoui B.
de Sèze R.
Sienkiewicz Z.J.
Simko M.
Vijaylaxmi
Zeni O.

Vice-Chair ICNIRP, AGNIRICNIRP, AGNIRICNIRP
Chair ICNIRP

Formerly AGNIRICNIRPICNIRPICNIRPAGNIR
ICNIRPAGNIR

ICNIRPICNIRP, AGNIR

still be causing, because they have not been accurately
informed of the risks. This has been a safeguarding failure
and the health of some children or adults may have beendamaged as a result. To prevent further possible harm,
restrictions on exposures are required, particularly forchildren, pregnant women and individuals with medical
conditions. All children in schools and care environments
need protection from the potential harmful effects of RF
exposures and not, as is now often the case, a compulsory
use of wireless devices in the classroom. Children may
unjustly face losing their human right to an education if
they do not want to absorb RF fields every day at schooland no alternative environments are available. Attention
also needs to be given to the provision of safe working
environments for employees and safe public spaces, particularly where exposures are involuntary.
PHE and AGNIR had a responsibility to provide
accurate information about the safety of RF fields.
Unfortunately, the report suffered from an incorrect andmisleading executive summary and overall conclusions,
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inaccurate statements, omissions and conflict of interest. Public health and the well-being of other species in
the natural world cannot be protected when evidence ofharm, no matter how inconvenient, is covered up.
Conflict of interest statement: The author states no conflict of interest.
Ethical approval: The conducted research is not related toeither human or animal use.

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Supplementary Material: The online version of this article(DOI: 10.1515/reveh-2016-0060) offers supplementary material,
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