Hebrew University-Hadassah
School of Public Health and Community Medicine
Unit of Occupational and Environmental Medicine
http://www.md.huji.ac.il/depts/occenvmed/
tel 972-2-6758147 fax 6437219
elihur@ekmd.huji.ac.il , stein444@gmail.com
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 of Comment on Smart Meter Report

I have been invited by colleagues to submit my Commentary on CCST Report andRecommendations for Smart Meters using RF. My comments are based on theinformation summarized in the Bioinitiative Report and the Seletun Reports, as well as
the other reports in the recent scientific literature, The broader context for mycommentary are the consequences of our past failures in environmental epidemiology
to heed early warnings from other many population wide exposures in yesteryear,
notably lead.
Personal Background: I am a medical epidemiologist who has assessed sourceexposure-effect relationships for many chemical and physical agents over the past 40years. This work has included work on lead, asbestos and smoking, pesticides,solvents, air pollution, and mixed exposures and ionizing radiation. Since the late1980’s I served as Head of the Unit of Occupational and Environmental Medicine inHebrew University-Hadassah School of Public Health and Community Medicine in1

Jerusalem Israel. I have also been involved in issues having to do with the medicalethics in public health, and served for several years as Chairman of the Ethics andPhilosophy Committee of the International Society for Environmental Epidemiology andI am a member of the Collegium Ramazzini. I have published more than 100 scientificpapers in the peer reviewed literature. Since the 1980's, I have had the opportunity toassess the case for a cause effect relationship with many workers with past cancer andpast severe exposures to RF/MW, often after short latent periods. I have alsosupervised 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 withextremely high occupational exposures to RF. I helped draft the Benevento andSeletun statements. In recent years, I have been particularly active assessing the useand scope of the Precautionary Principle in examining the anticipated risks fromalternative technologies.
1. Smart grid networks, if using RF, will generate 24/7 round the clock ubiquitous
involuntary indoor exposures to RF – in the everyday background environment ofeveryone in California in human habitats. The background exposures produced bythese grids will be substantially greater than those from point source WI-FI routers,
microwave ovens and cell phones. These whole body exposures, though perhaps
below levels of current regulatory standards, (INCRIP-WHO, and IEEE), will exceed
cumulative time weighted exposures producing the above outcomes, based on theliterature.
2. Based on the evidence in peer reviewed studies on the effects on these endpoints
and the exposure projections in Sage Associates’ landmark report (see Sage,
http://sagereports.com/smart-meter-rf/docs/Table7-8ElectricMeters_R1000_TA190Final.pdf ) this project exposes large percentages of the general population tohighly alarming involuntary exposure risk scenarios, taking into account an array ofmodifying factors e.g. background exposures, distance, reflection, and factors
influencing access to exposure areas.
3. Since the publication of the Benevento Resolution and the BioInitiative Report, thebody of evidence concerning health risks from exposures to RF continues toaccumulate. In particular from cell phone use. Cell phone use involves the deliveryof a high concentration of non-ionizing radiation to the skull and brain for relatively
brief periods of time over a 24 hour period as result of voluntary decisions byusers—a situation far less aggressive to the general population than involuntary
exposure from the proposed Smart Meters. Models for predicting penetration into
the whole body are now available, based on those developed by Gandhi and byKuster. These models draw attention in particular to the risks from exposure to theyoung.
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4. The exposures from Smart Meters are the equivalent of exposure of the entire
population—the young, the old, the newborn, the unborn, and the sick, toenvironmental tobacco smoke, even if most members of the population do notsmoke.
5. There is a huge body of evidence to refute the claim the so-called “hot muffin theory”
that there are no effects from sub-thermal exposures to NIR, and specifically RF/MW(Benevento Statement, BioInitative Report, London Report) The effects pertain to
ROS- Reactive Oxygen Species, cellular changes, effects on DNA, andneurobehavioral effects-- e.g. deficits in memory, mood changes, fatigue, headache,
as well as electro hypersensitivity and cancer, and effects on those with electronic
medical implants. It is important to note that there are also concerns about theproduction of dirty electricity, itself a risk factor for many of these outcomes(Milham).
6. Models of carcinogenicity or exposures to toxic and physical agents and cancer
postulate that we cannot be certain there is a threshold (based on the DNA single hit
model). These models also postulate roughly linear dose response relationships
and recognize groups and age windows for special risks—e.g. foetuses, newborns,
persons who are immunocompromised and those with sensitivities on the basis ofmechanisms which are still poorly understood. For populations, it is probable thatsimilar dose response models for exposure-risk relationships apply even thoughmechanisms involve resonance models of intensity and frequency.
7. It is fair to say that we are no longer talking about mere precaution of uncertain risk,
but about prevention of highly probable and known risks. Based on the accumulating
evidence, it is now fairly certain that there will be widespread adverse public healthimpacts. What remains uncertain is how many will be affected, and whether there
are time weighted intensity of exposure thresholds, below which there will beabsence of risk.
8. The most plausible scenario is that there will be 'small' increases in individual risk
for the incidence of occurrence (e.g. cancer) or incidence and severity (e.g.
neurobehavioral effects), applied to the entire population from these networks/ large
population wide increases in absolute numbers of people with adverse outcomes.
The epidemiologist Geoffrey Rose articulated the principle that small increases in
so-called sub-threshold exposures result in many more individuals with illness inthe entire population than high exposures delivered to small numbers of people. This
principle applies to the scenario of population-wide effects from exposures to RF
from networks of Smart Meters and concerns about dirty electricity.

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9. Were these population-wide exposures to smart meters to be part of a project
carried out in a medical setting, to test the risks and benefits of a new technology on
human health and well being, it would be rejected by a Medical Institutional Review
Board on ethical grounds as an unethical exercise in human experimentation.
10. The risks we are assessing today from exposure to RFMW and dirty electricity
from Smart Meters placed everywhere recalls the story of population-wide
exposure to lead in gasoline – a subject concerning which I have much direct
personal experience. In the 1970s, a mere 35 yrs ago, we were arguing as towhether or not an everyday blood lead level of 30ug/dl was a health risk. By 1979,
that threshold dropped to 20ug/dl and thereafter through the 1980s to 10ug/dl forchildren, and now we are not certain whether there is a threshold below which
there are no discernable adverse neurobehavioral effects, especially for in utero
and newborn exposures. We now know, in retrospect, that the entire urban
population, notably children, were receiving exposures which were impairing theirIQ, emotional well being, and long term growth and development. These findings
led to the elimination of lead from gasoline. In retrospect, we were not heeding theearly warnings regarding an impending population-wide hazard with disastrous
effects. I suggest that in the case of population-wide exposure to RF, the situation
is similar, with one exception: The warnings may no longer be early.
11. Population-wide exposure to man-made NIR represents a scenario relatively new
in the history of biology. It is difficult to assess risks from these new exposures andtheir frequencies and wave patterns using experience based on exposure to
background naturally occurring NIR. Instead, we are required to rely on
experimental studies and epidemiology of exposure-effect relationships, using
endpoints such as effects on stem cells, leaks from the blood brain barrier, as wellneurological, cardiac and cancer endpoints. In addition, there are additional
vulnerabilities to the eyes and to the testes.
12. I warn that we may be on the cusp of a similar scenario here with regard tocommunity wide exposures to RF/MW and dirty electricity from Smart Meters —with one exception: there are safe alternatives.
13. The Precautionary Principle, in its various formulations, specifies that where there
is uncertainty concerning the possibility of health risks from a new technology, thecosts of doing nothing to prevent the exposure (e.g. a false negative) may begreater than a false positive (taking preventive action). I add that in applying thePrecautionary Principle, we are required to weigh the risks and benefits from 3
options: doing nothing (i.e. no Smart Meters), and doing something (Smart Meterswith RF) or a different kind of Meters using fiberoptics. We recognize that doing4

nothing carries itself certain risk having to do with the operations of the electricalssgrid system.
But alternative technology- smart meters powered by fiber optics,
which are without known risk, can be used to achieve the same objective.
14. There is no excuse for avoiding this investment with a permanent enduring
protection for the public in avoiding and not introducing fiber optics. For reasons
just stated, it will be bad ethics and bad technology and, possibly wanton
negligence, recklessness and incompetence to wilfully forego the last option.

I thank the Commission for the opportunity to submit my comments.

Elihu D Richter MD, MPH (Assoc Professor)

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References:
1. BioInitiative Working Group, Cindy Sage and David O. Carpenter, Editors. BioInitiative Report: A Rationalefor a Biologically-based Public Exposure Standard for Electromagnetic Fields (ELF and RF).
www.bioinitiative.org. August 31, 2007.
2. Pathophysiology Journal, Special Issue 16: Volumes 1 and 2, 2009. Elsevier Press. There are chapters on
low-intensity radiofrequency and wireless radiation health effects based on scientific literature from the realmsof 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.
3. WHO Research Agenda, 2010. WHO research agenda for radiofrequency fields, © World HealthOrganization 2010
4. REFLEX, 2004. Risk Evaluation of Potential Environmental Hazards from Low Frequency Electromagnetic
Field Exposure Using Sensitive in vitro Methods.
5. Markova E, Malmgren LOG, Belyaev IY. 2009. Microwaves from mobile phones inhibit 53PB1 focus
formation in human stem cells stronger than in differentiated cells: Possible mechanistic link to cancerrisk. Environmental Health Perspectives On-line. 22 October 2009. doi:10.1289/ehp.0900781
6. Belyaev IY, Markovà E, Hillert L, Malmgren LO, Persson BR. 2009. Microwaves from UMTS/GSM mobilephones induce long-lasting inhibition of 53BP1/gamma-H2AX DNA repair foci in human lymphocytes.
Bioelectromagnetics 30: 129-141
7. Sage C, Carpenter D.O. 2009. Public Health Implications of Wireless Technologies. Pathophysiology 16:
233–246.
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 andGSM modulated radiofrequency: studies of proliferation, apoptosis and mitochondrial membrane potential.
Radiation Research 162: 211-218.
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. Electromagnetic6

Biology and Medicine 27:103–126.
10. Velizarov S, Raskmark P, Kwee S. 1999. The effects of radiofrequency fields on cell proliferation are nonthermal, Bioelectrochem Bioenerg 1999; 48: 177-180
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, Bioelectromagnetics 17:144-153
12. Zwamborn APM, Vossen SHJA, van Leersum BJAM, Ouwens MA, Mäkel WN. 2003. Effects of global
communication system radio-frequency fields on well-being and cognitive functions of human subjects withand without subjective complaints, TNO-report FEL-03-C148; 148:1-89
13. Sage Associates, 2011. Assessment of Radiofrequency Microwave Radiation Emissions from SmartMeters. http://sagereports.com/smart-meter-rf/
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. Basic & Clinical Pharmacology & Toxicology 102:73–75.

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