Chapter 4 - Australian standard on radiofrequency fields exposure levels
Uncertainty about potential of low intensity,
long-term exposure to RF from telecommunications technology was found by the
Committee to be the basis of the continuing argument for a sensible
precautionary approach (principle). With the inadequate research data
currently available, it has not been possible to estimate or quantify with any
degree of accuracy the extent of a safety margin that needs to be prescribed in
standards to be properly protective of the risk to the public.
Central to the question of the adequacy of our
standards was whether or not they dealt with non-thermal emissions which have
been shown by a growing body of research to show biological effects. Dr Michael Repacholi of the
World Health Organization explained that the scientific studies on which our
standards are set were observations of behavioural change in primates exposed
to heat emitting devices. The Committee Chair found the progress of standard development
to have been somewhat arbitrary and inadequate in dealing with non-thermal
The Committee stresses in Chapters 3 and 4, the
necessity for research to be carried out into the mechanisms of interaction of
telecommunications frequency microwaves with biological tissue. This research
must operate independently of influence by industry, government or regulatory
bodies. Without basic science data the Committee found that it is not possible
for anyone to predict what adverse health outcomes might occur.
Development of the standard
The Australian Standard, first published in
1985, deals with human exposure to radiofrequency fields. It was developed and
subsequently revised by a technical committee of Standards Australia. The
technical committee did not reach agreement on the last revision of the
Standard in 1999, which sought to introduce the more lenient ICNIRP Guidelines,
and the responsibility for setting a new standard was transferred by the
Government to the Australian Radiation Protection and Nuclear Safety Agency
(ARPANSA) which will formally adopt the Standard as an ARPANSA standard and
incorporate it into its regulations once it is accepted by the ARPANSA
Radiation Health Committee.
In the meantime, both ARPANSA and the Australian
Communications Authority have legislative instruments in place to limit human
exposure to radiofrequency fields. These instruments (Radiocommunications
(Electromagnetic Radiation — Human Exposure) Standard 1999 and Australian
Radiation Protection and Nuclear Safety Regulations) are based on the limits
previously contained in the interim 1998 standard (AS/NZS 2772.1(Int):1998).
These limits represent a weakening of protection for both occupational and
Basis of Radiofrequency Standards
Radiofrequency signals were first used in 1895
and by the early 1920s broadcasting was becoming commonplace. At this time,
research was beginning to probe the potential for biological effects of radio
waves, effects on the nervous system, and other observations of harm such as
localised burns and electric shocks caused by direct contact with a conductor.
During and after the Second World War, the
effects of exposure to radiofrequency radiation became a matter of intense
study particularly in the then Soviet Union. Over time, military applications became more powerful and the
frequency range used grew. As higher power uses of radiofrequency developed,
its ability to cause serious burns became evident. The US Military devised
criteria based on tolerable thermal loadings
According to Dr David Black, a medical
practitioner, specialist in the health effects of radiofrequency radiation, and
telecommunications industry consultant, in the early 20th century there had not
been the same concern about radiofrequency radiation as there had been about
ionising radiation, and it took longer for controls to be put in place:
Right up until the Second World War, people accepted that RF
could cause burns and electric shocks at high levels, but it was not really
until after the Second World War and the 1950s that people started thinking
that standards were needed to control these fairly obvious, and what are known
as, direct effects. Standards were developed originally on a bit of a rule of
thumb by just taking power flux density levels which seemed to be safe just
based on anecdotal experience at the time. Those formed the first standards
back in the 1950s.
The intensity, (or power density), of
electromagnetic fields can be expressed in terms of a unit of power relative to
area (eg watts per square metre - W/m2 or milliwatts per square
centimetre - mW/cm2).
It was recognised that experimental animals died quickly at exposures of
100 milliwatts per square centimetre (100 mW/cm2) and that
the primary mechanism for injury was related to excess heating resulting from
the absorption of the microwave energy in various tissues within the body.
In 1953, the US Navy adopted a maximum
continuous exposure limit of 10 milliwatts per square centimetre (10 mW/cm2)
for all radiofrequency and microwave frequencies in use. This limit avoided
burns and was a tenth of the level where short term fatal effects had been
observed in experimental animals. The level is equivalent to 10,000 microwatts
per square centimetre (10,000 TW/cm2). This exposure level was later accepted by the
entire US military and, in 1966, by the American National Standards Institute
The concept of safety in these early military
and later ANSI standards was very basic and the concepts of dose that are used
today are still based on thermal or heating effects and the SAR concept of
dosimetry that is applied is flawed.
According to the ARPANSA draft standard, early exposure standards were
inadequate because they failed to account for important physical aspects of
electromagnetic wave interaction with the body. In addition to the magnitude
of the applied fields, absorption of radiofrequency energy depends on the
physical geometry of the body relative to the direction of the applied fields
and also upon frequency dependent electrical properties of the absorbing
tissue. In particular, the body, or parts of it, can act like a tuned antenna
with specific radiofrequency bands. This concept still fails to take into
account more subtle interactions with biological systems that have nothing to
do with the effects of absorbed energy being turned into heat.
The most damaging frequencies according to the
SAR dosimetry model are those at resonance range of the human body which occurs
at frequencies between about 30 megahertz (30 MHz) and 300 megahertz (300
MHz). This means that electromagnetic fields in this frequency range approach
or coincide with the natural frequencies in the human body. This maximises
their penetration of tissue and the absorption of energy in the body. The precise
resonant frequency varies with individuals depending on their size and their
orientation in relation to the field. An average man in free space has a
resonant frequency of about 66 MHz. For taller individuals, the resonant
frequency is somewhat lower, and for shorter adults, children, babies and
seated individuals, it may exceed 100 MHz.
Dr John Holt, Medical Clinician and Director of
the Microwave Therapy Centre in Perth, pointed out in his evidence that cancer
is electrically conductive, and that cancer, when exposed to 434 MHz, will
resonate and fluoresce. Dr Holt informed the Committee that Professor Joines
of the US discovered that at 180, 200 and 300 MHz cancerous tissue was six
times more conductive than normal tissue.
Biological responses from exposure to
radiofrequency fields do not merely depend on the intensity of the fields
outside the body, but on the subtle effects of the electromagnetic energy on
the blood forming immune, nervous and endocrine systems inside the body.
Exposure to a uniform electromagnetic field results in a highly non-uniform
deposition and distribution of energy within the body. Research has shown that
electromagnetic fields can be divided into four ranges, as regards absorption
of energy by the human body which illustrates the inadequacy of the SAR dosimetry system. It
is currently assumed that different frequencies have different bioeffects
because of the heating effects they cause. These frequency ranges and effects
- from about 100 kilohertz (100 kHz) to less than about 20
megahertz (20 MHz) (sub-resonance range), at which absorption in the trunk
decreases rapidly with decreasing frequency, and significant absorption may
occur in the neck and legs;
frequencies in the range from about 20 MHz to 300 MHz (the resonant
range), at which relatively high absorption can occur in the whole body, and
even higher values if partial body (eg head) resonances are considered;
- frequencies in the range from about 300 MHz to several gigahertz
(GHz), (hot spot range) at which significant local, non-uniform absorption
occurs. The size of these ‘hot spots’ decreases from several centimetres to
about 1 cm as the frequency increases; and
- frequencies above about 10 GHz (surface absorption range), at
which energy absorption occurs primarily at the body surface.
Specific Absorption Rate (SAR)
During the 1950s, a dosimetric approach was
being developed for chemical safety and nuclear safety. Dosimetry is the
science of measuring exposure to an agent - whether that be a chemical or an amount
of radiation. This approach was extended to non-ionising radiation research
and resulted in the development of the concept of specific absorption rate
(SAR), which defines the amount of power absorbed per body mass. It is
measured in watts per kilogram (W/kg) and is the basis of high frequency
standards today. The SAR is the rate of absorption of radiofrequency energy in
a unit mass of tissue. It represents the energy actually absorbed and as such
is one indicator of the effect of the dose of radiofrequency energy.
In the SAR system, the total amount, the
distribution, and the rate of absorption of electromagnetic energy in a living
system are the function of many factors. The quantities of energy, internal
electrical field strength, induced body current, induced current density, and
specific absorption rate are all interrelated. The SAR is commonly used for
comparisons of biological effects under different exposure conditions. It can
be used to determine the internal (absorbed) energy distribution.
There are problems with access to measurement
with the SAR system. The SAR cannot be readily measured in routine exposure
assessment, but requires special techniques to determine it, either in the
laboratory or with computer estimations. It was not until the development of
reasonably powerful computers and other technologies (such as high sensitivity
thermal imaging cameras) in the mid 1970s, that significant advances could be
made in the radiofrequency dosimetry area.
When the SAR is not known, characteristics of the radiofrequency field
(eg power density, electric field strength, magnetic field strength,
polarisation) are used to estimate exposure. These measurements are more
readily available to people and give a reasonable and more practical idea of
whether or not the levels present are hazardous.
In tissue, the specific absorption rate depends
on the internal electric field strength. Average SAR and SAR distribution can
be computed or estimated from laboratory measurements. Values of SAR depend on
the following factors:
the electromagnetic field parameters, ie, the frequency,
intensity, polarisation and distance of the source from body it intercepts;
- the characteristics of the exposed body, ie, its size and
internal and external geometry, and the non-conducting (dielectric) properties
of the various tissues; and
- ground effects and reflector effects of other objects in the
field near the exposed body.
Work on specific absorption rate had settled on
4 watts per kilogram (4 W/kg) as a level of exposure which could result in
an experimental rise in core body temperature of up to 1°C. A rise in core
body temperature of more than 1°C is not well tolerated by the body and
produces deleterious effects. Thermal Standards are based only on the relatively
basic idea of preventing core body temperature increases and aim to keep
exposures to radiofrequency fields below these levels. A factor of 10 was
incorporated into where thermal effects were observed and this is the basis of
the original benchmark of 0.4 watts per kilogram in the standards today. The body is made up of very
different tissue types and the absorption varies giving quite unpredictable
internal temperature increases so the measurement system leaves a considerable
margin of uncertainty about what is really going on inside a human body exposed
to radiofrequency radiation.
Given therefore the complexity and variability
of the resonant properties of the human body, the Committee Chair questions the
efficacy of artificial modelling as an adequate tool to define safety levels in
Standards Australia International Limited
Standards Australia International Limited
(Standards Australia) is recognised as Australia’s peak national standards body
through a Memorandum of Understanding with the Commonwealth Government. It was
founded as an association in 1922 under the name of Australian Commonwealth
Engineering Standards Association, but was changed to Standards Association of
Australia in 1929. In 1950, the Association was constituted as a body
corporate and politic, by way of a Royal Charter, and in 1988, the trading name
Standards Australia was adopted. In 1999, it became an independent company and
adopted the name Standards Australia International Limited.
Standards Australia prepares and publishes most
of the voluntary technical standards used in Australia. These standards are
developed through an open process of consultation and consensus, in which all
interested parties are invited to participate. According to Mr Colin Blair
from Standards Australia:
... Standards Australia is a facilitator of a process for the
development of standards which brings together experts from representative
interest groups that work to formulate or revise standards. Standards Australia
is a facilitator. We do not play an active part in the decisions of the
committee, we do not have a vote on any standards that are prepared and we do
not chair meetings.
Although standards developed by Standards
Australia are voluntary, they do become mandatory when referred to in
legislation. This has occurred with the radio-frequency fields exposure
Standards Australia Technical Committee TE/7
To formulate standards, Standards Australia
convenes a technical committee representative of relevant stakeholders, by
securing the participation of those interested parties concerned with a
particular project. The majority of individuals who serve on technical
committees are representatives of sectors of interest nominated by government
bodies, industry associations, community-based and consumer organisations,
trade unions and professional, technical or trade associations. Such technical
committees should operate under internationally accepted principles of
transparency and consensus.
Standards Australia informed the Senate
Committee that when nominees of organisations are appointed as committee
members, it is their duty to ensure that their nominating organisations are
kept informed of committee activities. Committee members are required to
represent the views of their nominating organisations at the technical
committee meetings, not personal or company views. Individuals, however, do
not represent their employers, but they do represent the sectional interests of
their employers. It is accepted that they will use the resources of their
particular organisations to assist in the preparation of the most appropriate
The Standards Australia technical committee
responsible for considering standards for human exposure to electromagnetic
radiation is the TE/7 Committee. It was established in 1984 and has been a
joint Australian/New Zealand committee since 1992.
Four standards have been published as an outcome
of TE/7 deliberations:
- AS 2772.1:1985 Radio frequency radiation - Part 1: Maximum
exposure levels - 300 kHz to 300 GHz;
- AS2772.1:1990 Radiofrequency Radiation - Part 1: Maximum Exposure
Levels - 100 kHz to 300 GHz;
- AS/NZS 2772.1(Int):1998 Radiofrequency fields - Part 1: Maximum
exposure levels - 3 kHz to 300 GHz (commenced in March 1998 but was withdrawn by
TE/7 vote, effective from 1 May 1999); and
- NZS 2772:Part 1:1999 Radiofrequency fields - Part 1: Maximum
exposure levels - 3kHz to 300 GHz (effective from 1 May 1999 - New Zealand
Because of the level of public concern about
proposals to weaken the principles of radiation protection and increase the
amount of radiation that Australians can be exposed to, no agreement was
reached and so the increases were partly introduced by stealth when AS/NZS
2772.1(Int):1998 was issued as an Interim Standard before being finalised to
allow further committee review and public comment. The subsequent public
disquiet however, ended with the interim standard being withdrawn with effect
from 1 May 1999 (see below).
Standards Australia Processes
Mr Blair, from Standards Australia, informed the
Committee that the process of developing standards has three main components:
The first component is that it is an open and transparent
process. The second component is that we have a balanced representation on our
committees. This balance is a cross-section of all organisations that would
potentially be used or influenced by the standard. Generally, when we look at
that balance, we split it into groups along the lines of user, purchasing
bodies, manufacturers-suppliers, independent professional and technical bodies,
consumers, regulatory or controlling bodies, research and testing organisations
and unions. The third component of our process is consensus. Really, the
important part of the consensus process is when the formal postal ballot takes
place after the document has been developed and been through the public comment
In order for a Standard to be published, there
are three conditions that need to be met:
- 67 per cent of people who are eligible to vote, do actually vote
on the document;
- of those who have voted, 80 per cent must be supportive of the
- even if the 80 per cent positive vote is achieved, no major
sectoral interest is to maintain a negative vote.
Standards Australia argued that, through an open
and transparent process, balanced representation on the committees and the
consensus requirements, fair and reasonable documents are published at the end
of the day. If consensus is not reached, the documents are not published.
History of the Australian Standard
Following the US military, a limit of 10,000
microwatts per square centimetre (10,000 TW/cm2)
had been informally adopted in Australia through various guidelines and rules
imposed by most radiation generating authorities between 1955 and 1979, but there
was no Australian Standard as such until 1985.
Australian Standard AS 2772: 1985, Maximum Exposure
Levels - Radio-Frequency Radiation - 300 kHz to 300 GHz
In formulating AS 2772: 1985, the Standards
Association of Australia technical committee (TE/7) reviewed but found
inadequate an American National Standards Institute (ANSI) proposal for
exposure limits in the frequency range 300 kilohertz (300 kHz) to 100 gigahertz
The 1985 Australian Standard took a conservative
approach to setting exposure levels. It differed from the maximum exposure
levels proposed by ANSI by choosing lower exposure levels for the higher and
lower frequency ranges; and an averaging time of one minute was adopted for all
exposure conditions, regardless of the field strength, rather than the six
minute averaging time suggested by ANSI. It also contained reference to the
ALARA Principle whereby all doses should be kept as low as reasonably
achievable, economic and social considerations being taken into account.
Another useful feature of the 1985 Australian
standard was to establish reduced exposure limits for the general population
than for the occupationally exposed population. This is because the
occupationally exposed population consists of adults who are exposed under
controlled conditions, and who are supposed to be trained to be aware of
potential risks and to take appropriate precautions. The duration of
occupational exposure is limited to the length of the working day or duty shift
per 24 hours, and the duration of the working lifetime.
The general public (the non-occupationally
exposed population) comprises individuals of all ages and different health
status. The resonant range is different for adults and children and so is the
distribution of radiofrequency energy absorption in various body parts. Some
individuals may be particularly susceptible to radiofrequency radiation. In
addition, members of the public are not always aware that exposure takes place
and they can be exposed 24 hours per day, and over their entire lifetime. They
cannot reasonably be expected to take precautions against radiofrequency and
particularly burns and shocks. For these reasons lower basic (and derived)
exposure levels are adopted for the non-occupational population than for the
occupationally exposed population.
The limits set out in the 1985 Standard are
specified in basic restrictions which affected industries argued were difficult
and, in many cases, impractical to measure
Dr Repacholi, suggested that the exposure levels
in the Australian standard for the microwave region of the spectrum were set at
levels which owed more to negotiations between the various parties than to the
I was involved in the early attempts to develop an Australian
standard. The standard was developed primarily on the international standard at
the time and follows the international standard except in one region, called
the microwave region. There was so much discontent about this that the level
ended up being a negotiated level. It was not based on the science. Everything
was based on the science up to that point, but the last part was not based on
the science - it was negotiated between the unions and the government at the
According to Mr Alexander Doull, a member of the
TE/7 Committee, the 1985 Australian Standard tightened and reduced the then
allowable exposure limits and incorporated explicit, fundamental principles of
radiation safety. It also explicitly acknowledged:
- the limitations of a standard based only on preventing heating
and burns; and
- a possibility of harmful non-thermal effects on living systems.
The CSIRO informed the Committee that in recent
years there have been various attempts to relax the acceptable limits of
radiofrequency exposure in the Australian Standard. The rationale has been to
align it with international guidelines although, according to the CSIRO, there
is no substantial new scientific evidence on which to base such a proposed
Mr Doull suggested that since 1985, the
Australian Standard has come under sustained industry pressure to revert to
much higher levels of exposure to radiofrequency radiation; to completely
delete any references to fundamental principles of radiation safety; to
minimise any explicit references to harmful effects; and to delete the previous
acknowledgment of the existence of non-thermal effects on living organisms. He believes that the changes
in the official Standard that the industry has wanted would probably have the
effect of protecting the industry from future litigation. Mr Doull referred to
a precedent setting case of fatal microwave disease in New York which had been
the first jurisdiction to recognise asbestos diseases in exposed workers.
In response to earlier questioning by the
Committee about the issue of litigation, Dr Hugh Bradlow from Telstra, replied:
I presume we have adequate liability coverage and, given that
there is no identified effect, it is very hard to take out insurance against
something that does not exist.
The 1985 Standard had excluded devices which
operated below 1 GHz and had a power output of below 7 watts from compliance
with the Standard. It was decided that it would be unlikely that these devices
could couple enough energy into any size human body such that the average whole
body SAR of 0.4 W/kg would be exceeded. In addition, it would not be expected
that there could be any spatial peak SAR in the human body exceeding 8 W/kg
averaged over any one gram of tissue this value being lower than spatial peak
SAR which could arise when whole body exposure occurs at the maximum exposure
In 1988, the Standard was renamed Australian
Standard 2772 - 1985 Radio Frequency Radiation Part 1 - Maximum Exposure Levels
- 300 kHz to 300 GHz.
AS2772.1-1990: Radiofrequency Radiation Part 1: Maximum
Exposure Levels - 100 kHz to 300 GHz
The 1990 Standard superseded the 1985 standard
and introduced changes which included extension of the frequency range down to
100 kHz, and included limits for body-to-ground radiofrequency currents.
However, the limits for exposure to radiated fields for both occupational and
non-occupational exposure remained unchanged.
AS2772.1:1990 provided a ‘deemed to comply’
provision for all radiocommunications transmitters like mobile phones operating
below the frequency 1 GHz. If the output power of the transmitter was
less than 7 watts, the device was deemed to comply with the Standard. Concern
was expressed that, because of the proximity of the radiating antenna to the
head, mobile phones on the market were exceeding the exposure limits of the
Standard for the general public despite being deemed compliant.
In 1994, Amendment 1 introduced various
corrections and changes, in particular, more explicit requirements for exposure
limits for users of transmitters, including hand-held and mobile transmitters. It also lowered the deemed to
comply threshold for hand-held digital mobile phones to 0.7 watts and
introduced a requirement to label devices.
AS/NZS 2772.1(Int):1998 Interim Australian/New
Zealand Standard, Radiofrequency fields Part 1: Maximum exposure levels - 3 kHz
to 300 GHz
A periodic review on the 1990 Standard was begun
in 1993 but agreement was not reached as the proposals put forward by industry
were to significantly increase allowable exposure limits. It was therefore
released as an Interim Standard, AS/NZS 2772.1(Int):1998, while being further
The Interim Standard was based on the
International Radiation Protection Association (IRPA) Specific Absorption Rate
(SAR) Guidelines, but covered an extended frequency range down to 3 kilohertz
(kHz). The basic limits (whole body average SARs) between the Interim Standard
and its predecessor standards did not change - occupational exposure limits to
radiofrequency fields were based on 0.4 watts per kilogram (0.4 W/kg)
and the non-occupational exposure limits were derived from values one-fifth (or
less) those of the occupational limits (that is 0.08 W/kg).
However, there were changes in the derived
exposure levels in the frequency range around 1 megahertz (1 MHz) to bring the
Interim Standard into line with the recommendations of privately controlled
international bodies. On the other hand, the derived exposure levels in
relation to frequencies between 400 MHz and 2 GHz were set lower than other
International Standards, in accordance with the precedent set in the 1985
Standard. Evidence suggested that the IRPA/ICNIRP methodology would lead to
progressively rising derived levels and thereafter to a level which is constant
with frequency between 400 MHz and 2 GHz. The TE/7 Committee did not support
The Chairman of TE/7 Committee, Dr Repacholi,
proposed to use, as the basis for the Australian Standard, the World Health
Organisation review of scientific literature which he had edited for the WHO.
This WHO publication recommended the international guidelines on exposure
limits published by the International Radiation Protection Association (IRPA
The Interim Standard was criticised by those
concerned with the public interest because the limits were to be relaxed, and
the peak exposures diluted by the use of the six minute averaging time rather
than the 1 minute averaging time in the 1985 standard. The non-uniform
exposure levels were also criticised.
One of the major objections to the standards was
that they only take account of thermal effects of exposure to radiofrequency
radiation, and not to non-thermal effects. The Electromagnetic Radiation
Alliance of Australia states that:
The existing standard is based on the erroneous presumption that
adverse health effects occur only if the body is heated by 1°C.
There is ample evidence that adverse effects occur at much
lower, or athermal, levels that do not require heating of the body.
Dr John Moulder, Director of Radiation Biology
at the Medical College of Wisconsin, USA, emphasised how difficult it is to
separate the thermal effects from any non thermal effects:
It is probably absolutely impossible to prove that there is
absolutely no heating, but with enough engineering wizardry you could probably
establish that there could not be very much heating.
The Mobile Manufacturers Forum argued that
standards-setting bodies do not ignore the non-thermal effects in their
We would like to stress that when these standards bodies review the
research they are looking at all the research, not just the established effects
but the non-thermal as well as thermal effects ...
Dr David Black informed the Committee that the
ICNIRP Guidelines do take athermal effects into account. He cited the example
of neuro-stimulation which is the biological effect which, at low frequencies,
is the effect that the exposure levels in the Guidelines aim to prevent.
Neuro-stimulation can be generally regarded as an athermal effect.
According to Mr Dan Dwyer from the Communication
Electrical Plumbing Union, the use of derived exposure levels can result in an
increase in exposures:
What is disappointing is that all the research since the last
standard was introduced appears to be aimed at exploiting the basic restriction
(a rise in temperature by 1 degree) to the limit. Thus we have had to consider
proposals from the manufacturers/telecoms for complex analysis of absorption
rates at higher frequencies, averaging time, pulsed transmissions and even
pregnant women. Whilst these studies may be mathematically consistent, it is
inconsistent with a precautionary approach.
Dr Repacholi however, disagreed with the need
for any inclusion of precautionary principles and would have it that in
Australia we are confused and wandering from the path of science:
There is a confusion in the Australian standard at the moment.
It says that the standard is 0.08, but in fact it is not. The limits that came
out were not 0.08. Down here it is about 0.01. If you stick to the basic
standard it will not be a relaxation. If you stick to the limits that were
identified to get that, then yes, it will seem like a relaxation.
It [the standard] partly follows the science in the absorption
curve. As you increase the frequency, the absorption changes and, at this
point, it departs from the normal absorption curve, which is well known and
well established in science. The shape of the standard should follow the normal
absorption curve for human beings. The negotiated point is the only point of
departure from the science.
When questioned about the consequences of
setting a Standard which departs from his view of the science, Dr Repacholi
There is no effect on health. It is just that, from my
viewpoint, I would like to see something that is science based and take away
the subjectivity or the various opinions of people. Health is not negotiable;
it should be based on something that is substantiated so that you know what
level of protection you are providing to people.
However the Committee Chair considers that the
science is divided and uncertain at best and the mounting evidence of cancer
risk associated with electromagnetic field exposures is of concern to rational
people and that it is not responsible to increase human exposures in these circumstances.
Dr Repacholi advocates that Australia adopt
international limits in line with standards world wide. The Committee notes
that this campaign has not won universal support but industry groups favour
this approach. The Australian Mobile Telecommunications Association (AMTA)
From an industry’s point of view, it is more efficient to
provide consumers with safe and technologically advanced wireless communication
devices if there is an opportunity, as now, to adopt the internationally
accepted ICNIRP guidelines.
However, in its submission, the CSIRO observed
[t]he limits in the 1985 Australian Standard AS2772 were in
place for more than 12 years and did not inhibit the introduction of new
technologies or the extension of existing technologies.
Mr Les Dalton provided the Committee with an
example of where lower standards actually operate to encourage technological
It is the same story with the exposure to magnetic field
emissions from computer screens. Sweden was the first to set a standard of 2.5
milligauss for the electrofrequencies which come from the transformer of
computers. This maximum was eventually adopted because schools in the United
States, among others, insisted that this be their standard, too. The outcome
was that they would not accept computers in schools unless their emissions were
less than 2.5 milligauss. Eventually, that became the accepted standard. It
only took the industry about 12 months to all be below that, because the
technology was there to do it. It turned out that IBM had had a patent for five
years to enable them to do it but had not done it. So a rigorous standard is
always an encouragement for technological excellence.
Faced with opposition to increased exposures
AS/NZS 2772.1(Int):1998 introduced different ‘deemed to comply’ provisions for
handheld and portable transmitters. The new provisions were based not only on
output power, but also on the transmitter’s duty cycle and the body-antenna
separation distance. The result of the new provisions is that mobile phone
handsets need testing to demonstrate compliance with the Standard.
International Commission on Non-Ionizing Radiation
Protection (ICNIRP) guidelines
The international limits to which the World
Health Organization refers (above) are the guidelines drafted by the
International Commission on Non-Ionizing Radiation Protection (ICNIRP). The
ICNIRP was established in 1992 as a successor to the International Radiation
Protection Association (IRPA/International Non-Ionizing Radiation Committee (INIRC).
Industry always stresses the independence of the
Membership of ICNIRP is restricted to scientists working from an
independent academic basis, and the outputs of the committee are always
published in a highly respected peer reviewed biophysics journal, Health
Physics. As a result of following this process all of the outputs of the
ICNIRP committee are themselves subjected to peer review before publication and
normal scientific peer review after publication. In my opinion, this approach
is particularly satisfactory as it means that this information which is later
used to provide the basis for regulatory documents goes through a standard
scientific process of rigorous appraisal.
Dr Ken Joyner, from the Mobile Manufacturers
If you want to look at one standards body that has specifically
excluded any industry representatives, there is the ICNIRP body. You cannot be
a member of the ICNIRP panel if you are part of industry. They exclude you from
According to industry and government evidence
the ICNIRP guidelines on limiting exposure to non-ionising radiation are based
on comprehensive expert reviews of published scientific studies, and establish
principles of non-ionising radiation protection for formulating international
and national research programs. The ICNIRP used the World Health Organization
health risk assessments to derive the guidelines. The ICNIRP exposure
guidelines for protecting the public from the adverse health effects of
exposure to electromagnetic fields have been endorsed by the European
Commission and recommended for adoption within the member states of the
European Union (EU).
The ICNIRP guidelines specify basic restrictions
on exposure levels to radiofrequency fields. Depending on the frequency, the
physical quantities which are used to specify the basic restrictions on
exposure to EMF are current density, SAR, and power density.
Different scientific bases were used in the
development of basic exposure restrictions for various frequency ranges in the
- between 1 Hz and 10 MHz, basic restrictions are provided on
current density to prevent effects on nervous system functions;
- between 100 kHz and 10 GHz, basic restrictions on SAR are
provided to prevent whole-body heat stress and excessive localized tissue
heating; in the 100 kHz – 10 MHz range, restrictions are provided on both
current density and SAR; and
- between 10 and 300 GHz, basic restrictions are provided on power
density to prevent excessive heating in tissue at or near the body surface.
Reference levels of exposure (a different name
for ‘derived exposure levels’ which were used in the Australian standards) are
provided for comparison with measured values of physical quantities.
Compliance with all reference levels given in the guidelines ensures compliance
with the basic restrictions.
In setting limits, it was said that ICNIRP/IRPA
identified radiofrequency field values above which adverse biological effects
could be confirmed by laboratory studies. These values were used as benchmarks.
A safety factor of 10 was then incorporated so that workers would not be
exposed to more than 1/10th of the benchmark level. For the general public, an
additional safety factor of 5 was incorporated into the exposure limits.
Therefore the exposure limits for the general public are set at 1/50th of the
Because of the different ways in which
radiofrequency fields affect the human body depending on their frequency,
different parameters for field restriction are used at various frequencies
(refer to paragraph 4.15 above). The ICNIRP
Guidelines are said to identify the adverse effect which occurs at the lowest
level of exposure for differing frequency ranges and use this effect as a
limiting benchmark with an additional safety factor.
Dr Bradlow, Telstra, claimed that the changes in
reference levels (derived exposure levels) have come about because of an
improved understanding of the coupling
between radiofrequencies and biological systems since 1985. This allows the exposure levels
to be more precisely defined at the various frequency ranges.
The allowable general public exposure limits in
the Australian Interim Standard were similar to those in the ICNIRP Guidelines
except differences occurred in the higher frequencies where the lower levels in
the 1990 standard were retained.
Objections to the ICNIRP Guidelines
The recommended exposure limits in the ICNIRP
Guidelines take into account the fact that the effects of electromagnetic
fields on the human body can vary depending on their frequency. One of the
CSIRO’s objections to the levels in the ICNIRP guidelines was that they
increase for exposure to frequencies above 400 MHz. The CSIRO argued
that there were economic drivers behind the lifting of the allowable exposure
at the higher frequencies which happened, by ‘sheer coincidence’ to be around
ARPANSA informed the Committee that the reason
for the ‘dip’ in the ICNIRP exposure levels is that the frequency range between
10 MHz and 400 MHz covers the human body’s resonance range where the whole body
absorption of electromagnetic fields achieves a maximum value. Above 300 MHz
the fields are not so well absorbed by the human body.
Dr Neil Cherry, a New Zealand scientist and
academic, asserted that the ICNIRP Guidelines are not based on a public health
assessment of the evidence and they only take into account the thermal effects
of RF radiation. He claimed he represented many scientists in Europe in
criticising the ICNIRP Guidelines, saying that:
They decide that there is no evidence of genotoxicity but they
do not cite any studies that have been published that do show that RF
microwaves damage chromosomes – and that is the classic test of genotoxicity.
They do not even cite one study that is available in the literature that says
it damages chromosomes. Secondly, when I looked at two of their studies on
cancer, they said that two recent studies do not show any significant effects.
I have those studies and they do show significant effects. ... [I looked] at other
studies, and they similarly misused them or they took the author’s conclusion
when the data contradicts the author’s conclusion.
Mr Alexander Doull also suggested that
exposure limits are set to suit industry products rather than for health
reasons. He asserted that the refusal of TE/7 members to support the Interim
Standard was a rejection of:
... the practice of setting numerical safety exposure limits to
suit existing industry products and then dressing those limits up by
retrospectively applying an inadequate, crude, supposedly ‘scientific’
rationale for those limits. This practice enables the telecommunications
industry to increase limits bringing products like the mobile phone which
failed to comply with previous public exposure standards within the boundaries
of what can then be presented as responsible, acceptable and legally safe.
This view was echoed by Dr David Mercer in a
paper which he wrote on the radiofrequency standard setting process:
... the push for harmonisation with ICNIRP was in part stimulated
by the development of new RF-producing technological applications not covered
by the Australian and New Zealand standard but actually built with the ICNIRP
standard in mind. It was also suggested that exposures to these frequencies
were pushing standard setters to consider frequencies even less well understood
than existing ones.
Mr Les Dalton concurred when he related how the
existing radiofrequency standard was developed:
We had a CSIRO representative on the standard setting committee.
... He argued for a maximum public exposure of 40 microwatts per square
centimetre. The industry eventually insisted that it be 100. But then they
learned that some broadcasting antennas, and particularly one in Adelaide, were
well above that. So what happened was that they made it 200. That is the reason
we have 200 microwatts per square centimetre, today, for public exposure. It
had little to do with science.
Of the same view is Mr Don Maisch, EMFacts
consultant, who claimed that in one of the ICNIRP epidemiological studies the
high exposure group was diluted by the low exposure group and that this diluted
the final result.
The CSIRO does not believe that the Australian
Standard should more closely follow the limits proposed in the ICNIRP
The ICNIRP limits are based solely on known thermal effects, and
expressed as a maximum Specific energy Absorption Rate (SAR) in units of Watts
per Kilogram. SAR is a difficult quantity to measure directly, and derived
limits in terms of field-strength are often more useful. The field-strength
limits derived from the ICNIRP model are direct relaxations of the 1985
Australian limits over much of the frequency range. ICNIRP also proposes that
measurements be averaged over six minutes, which for intermittent or pulsed fields
is an indirect relaxation of the one-minute averaging time of the 1985
In February 2000, Switzerland introduced
stricter exposure limits in relation to emissions generated by stationary
Although the scope of the Swiss Ordinance is limited (for example, it does not
apply to emissions from mobile phones), the allowable exposure limits are many
times below those in the ICNIRP Guidelines. For example, for transmission
installations for cellular mobile telecommunication networks of more than 6
watts, operating at 900 MHz or 1800 MHz, the limit values for the rms electric field strength, are
4.0 volts per metre (4 V/m) and 6 volts per metre (6 V/m) respectively. These
levels are approximately 100 times stricter than the levels recommended in the
Claimed benefits of the ICNIRP Guidelines
The World Health Organization summarised the
benefits in achieving harmonised standards for EMF exposure as follows:
- increases public confidence that governments and scientists agree
on health risks;
- reduces debate and fears about EMF;
- ensures that everyone is protected to the same high level; and
- has economic benefits to trade that would result in benefits to
The Mobile Manufacturers Forum (MMF) enumerated
the benefits of harmonisation of standards, as it views them, for the
First of all, there is an increase in public health agency
confidence if there is only one standard and they are all saying the one
thing. Consumers also gain confidence from one standard for all consumers—if
there is no differentiation. The industry also gains because we can design a
product once, we can test a product once and we can make that product available
everywhere. The World Trade Organisation agreement requires international
acceptance of international standards when developing technical regulations
amongst member countries.
Dr Repacholi provided the example of the
radiofrequency standard in the United States. There, exposure levels are
higher than the international standard in many areas. The WHO feels that it
does not incorporate sufficient safety factors.
The Australian Mobile Telecommunications
Association (AMTA) supports a global standard and believes Australia should
adopt the international standard. It told the Committee that if this were
done, there would be the following benefits to consumers:
... products will be manufactured to the one standard and there
will be a consistency of information that will be provided that will be
important in terms of the SAR information. It will enable the manufacturers to
have the economies of start scale that will allow a product to come to the
market earlier and cheaper. We believe there are a lot of advantages to the
Events culminating in the Interim Australian/New
Zealand Standard expiring
The Interim Standard (AS/NZS2772.1(Int):1998)
superseded AS2772.1-1990 Standard, and introduced significant changes to
the exposure limits which had remained, till then, at the levels in the 1985
Standard (AS2772-1985). The increase in the public exposure levels allowed by
these changes was opposed by the CSIRO and some other organisations. According
to the CSIRO, it was because of this opposition that the Standard was published
as an Interim Standard, scheduled to expire in March 1999. During the lifetime
of the Interim Standard, Standards Australia attempted to persuade the TE/7
Committee to agree to a new standard.
Between August 1998 and April 1999, the TE/7
Committee reviewed the need for a revised Standard to replace AS/NZS
2772.1(Int):1998. According to the Interim Standards document, the particular
areas which the Committee was to review were:
- the treatment of non-thermal effects;
- the appropriateness of proposed radiation levels which are based
on current World Health Organization (WHO) recommendations; and
- the proposed measurement methods of time and spatial averaging.
Before the review began, the constitution of the
TE/7 Committee was changed to add three new nominating organisations to the
Committee, bringing the size of the Committee to 30 stakeholder
representatives. The new nominating organisations were: the Consumers’
Federation of Australia (2 seats), the Australian Mobile Telecommunications
Association (AMTA) (1 seat) and Cable and Wireless Optus (1 seat). The composition of TE/7
Radiation Controls Inc NZ
Faculty of Occupational Medicine
Radiation Protection Society
Council of Trade Unions
Electrical and Electronic Manufacturers Association
Mobile Telecommunications Association
Telecommunications Users Group
Communications Ltd NZ
Committee TE/3 - Chairman
Electrical Plumbing Union
Federation of Australia
of Communications and the Arts
Supply Association of Australia
of Engineers Australia
Government New Zealand
of Commerce New Zealand
Occupational Health & Safety Commission
Radiation Laboratory New Zealand
Zealand Association of Radio Transmitters
NZ Institute of Occupational & Environmental Medicine
New Zealand Limited
Institute of Australia
Balance - Number of committee positions
in each of the following groups
User and Purchasing Bodies
Independent Professional and
Regulatory or Controlling
* The two members of Standards Australia and Standards New
Zealand do not vote on the Standards.
The TE/7 Committee followed the accepted
Standards Australia/Standards New Zealand process in reviewing the Standard
which was said to have been done in the light of the most recent developments
both in Australia and internationally. Two formal Committee meetings were held
on 11/12 August 1998 in Sydney and 4/5 November 1998 in Wellington, New
Zealand. The Committee supported adopting the maximum levels of radiation
recommended by ICNIRP accompanied by a to-be-defined ‘precautionary approach’.
A new draft Standard (DR 98627 Radiofrequency
fields Part 1: Maximum exposure levels — 3kHz to 300 GHz) was prepared and
released for public comment for a period of two months between 1 December 1998
and 31 January 1999. Free public seminars to inform the general public of the
content of the proposed Standard were also held because of the public interest
in the subject. These took place in Sydney and Melbourne on 9 December and 10
December 1998, respectively.
The TE/7 Committee considered the public comment
and appropriate amendments were made to the draft. A major point of debate was
the strength of the proposed ‘precautionary approach’ given in clause 10 of the
Committee ballot draft.
A formal ballot of the TE/7 Committee was
conducted on the modified document. The vote closed on 4 March 1999 without
the Standards Australia/Standards New Zealand threshold of 80 per cent
acceptance being reached in either Australia or New Zealand. The result was:
ballot on draft standard DR 98627
A process of trying to change negative votes was
conducted in accordance with Standards Australia and Standards New Zealand
processes. The Interim Standard was due to expire on 5 March 1999 and this date
was extended by a vote of the TE/7 Committee to provide time for further
discussion. The currency of the Interim Standard was extended until 30 April
1999. Discussions were conducted with all TE/7 Committee members to try to
broker a compromise, but Australian members were not persuaded to change their
vote. The major sticking point was that negative voters wanted a stronger
precautionary approach, but supporters of the ballot draft would not agree as
they saw this to be in conflict with the ICNIRP guidelines.
New Zealand members met on 20 April 1999, when
changes to the ballot draft were passed by the necessary 80 per cent acceptance
(7 votes in favour, 1 vote against). The New Zealand members agreed that their
modified document would be put forward as a New Zealand-only Standard if
agreement could not be gained from Australian TE/7 members.
Agreement did not take place in Australia and a
ballot failed to agree to a further extension of the Interim Standard. It was
withdrawn on 30 April 1999 and the task of revising the Standard was removed
from the Committee’s responsibility. The TE/7 Committee has one project
currently in abeyance: that is, the EMR testing standard which is part 2 of the
AS2772 Standard. The future role of the TE/7 Committee is unclear.
Although there is now currently no Standards
Australia standard for human exposure to electromagnetic radiation, the former
Interim Standard continues to be mandated by ARPANSA and the Australian
Communications Authority for regulatory purposes.
According to Standards Australia it is quite
unusual for a Committee not to achieve consensus:
It is very rare that we have not achieved consensus. We publish
an average of 40 to 45 standards a month, every month of the year. In the last
six or seven years, I have not known us not to achieve consensus in publishing
standards. So this is a very rare event.
When asked by the Senate Committee how he
accounted for the failure of the TE/7 Committee, Mr Roger Lyle from Standards
I think if you have a look in detail at the actual process, it
really got down to the stage where they hardened their positions. Consensus
building means coming up with compromises. After the third meeting of the
committee, my view was that there probably would be an outcome. But a few weeks
later when the postal ballot was held it was fairly obvious that various
members on the committee had hardened their views, for whatever reason. For a
period of about six weeks there was an impasse. When we get into a situation where
we do not meet our hurdles we go through a process of trying to resolve the
issues. We ask people when they vote in the negative to actually provide the
reasons for that in order to help the committee try to work through compromises
to be able to reach a consensus. It was fairly obvious that people just were
not finding those compromises.
Despite the fact that the TE/7 Committee was
unable to achieve consensus in this instance, Dr Black argued that it should in
no way reflect on Standards Australia nor on its processes:
In my opinion the support from Standards Australia during this
time was particularly good, and the committee worked well. The limiting factor
was the fundamentally flawed idea that a scientifically based document could be
produced by a democratic process of requiring virtual consensus from a group
which deliberately included people with inevitably dissenting views.
Nevertheless, I have no doubt that this was originally done with the best of
The Committee notes that Standards Australia was
unable to provide the Committee with any adequate reason for not accepting the
negative votes from the dissenting members on whether or not to accept the
CHAIR: I think this goes to the heart
of the whole question: why was it not possible then, having not got over those
first two hurdles, to then say, ‘There is disagreement on this committee, so
let us stay with the current standards?’ Why was it necessary to find that
compromise and move on? What was the compelling reason for making the shift to
the new standard?
Mr Lyle: Our process obviously had to
come to some sort of conclusion.
CHAIR: Why couldn’t it conclude
with the decision for no change? Why couldn’t it say, ‘The committee does not
agree with this direction, and we want to stay with the existing standard?’
Mr Blair: To stay with the interim
CHAIR: Yes, or make the interim
standard the permanent standard.
Mr Lyle: We would not agree to it. It
was put to a vote.
Mr Blair: We went through that process
as well, and there was not agreement.
The Committee Chair is not persuaded that the
proposed new standard was a scientifically-based document, however, neither
have they found fault with the Standards Australia processes.
The Transfer of Responsibility for Setting a New
Australian Standard to ARPANSA
ARPANSA was established on 5 February 1999 under
the Australian Radiation Protection and Nuclear Safety Act 1998. The
object of the Act is to protect the health and safety of people, and to protect
the environment from the harmful effects of radiation. ARPANSA itself is an
amalgamation of the Australian Radiation Laboratory, formerly part of the
Department of Health and Aged Care, and the Nuclear Safety Bureau, formerly a
statutory authority. It comes under the aegis of the Department of Health and
ARPANSA sought nominations for its Radiation
Health Committee (RHC) Radiofrequency (Exposure Standard) Working Group from
more than 20 organisations. The final composition of the Working Group
(Exposure Standard) Working Group
Dr Colin Roy, Director, NIR
Mr Vitas Anderson, Private
Consultant, EME Australia Pty Ltd
Dr Stan Barnett, Project
Leader, Bioeffects of Non-Ionizing Radiation, CSIRO (has resigned)
Mr Wayne Cornelius, Head, EMR
Section, NIR Branch, ARPANSA
Mr Dan Dwyer, National Branch
Secretary, Telecommunications Officers Association, Communications,
Electrical & Plumbing Union
Dr Bruce Hocking, Consultant
in Occupational Medicine
Dr Ken Joyner, Director, EME
Strategy and Regulatory Affairs, Motorola Australia
Mr John Lincoln, Convenor,
Electromagnetic Radiation Alliance of Australia
Mr David McKenna, National
Organiser, Community and Public Sector Union (has resigned)
Dr Andrew Wood, Senior
Lecturer in Biophysics, Swinburne University
Ms Jill Wright, Senior
Inspector, Division of Workplace Health & Safety, Queensland Department
of Training & Industrial Relations
Dr David Black, Occupational
& Environmental Physician
Professor Mark Elwood,
Director, National Cancer Control Initiative
Mr Michael Bangay, Technical
Officer, EMR Section, NIR Branch, ARPANSA
Mr Alan Melbourne, Manager,
Standards Development Section, ARPANSA
Dr Graeme Dickie, Radiation
Health & Safety Advisory Council, ARPANSA
Mr Ken Karipidis, EMR Section,
NIR Branch, ARPANSA
Ms Judith Lawson, Manager,
Research Coordination Unit, Prevention Strategies and Facilitation Branch,
National Occupational Health and Safety Commission
Mr Ian McAlister, Manager,
Radiocommunications Standards, Australian Communications Authority
The ARPANSA Radiation Health Committee (RHC)
oversees the work of the Radiofrequency (Exposure Standard) Working Group by
setting the terms of reference and providing guidance and arbitration where
necessary. The RHC provides final approval of the Standard and may make
amendments at its own discretion.
Submissions were mixed when addressing this part
of the terms of reference. The telecommunications industry, the Australian
Communications Authority and other government agencies supported the
development of a new standard by ARPANSA:
It is the ACA’s view that given ARPANSA’s resources, experience
and statutory backing, it is most suited for the standard development task.
In addition, ARPANSA’s expertise in dealing with
radiation issues was thought to be invaluable:
... I believe that the interim standard should be revised to
include the ALARA Principle and that the responsibility for doing this should
be given to a body with more expertise in dealing with radiation matters, such
The Radiation Advisory Committee of the
Victorian Department of Human Services made the point that ARPANSA’s
international experience in setting standards would be valuable:
The RAC is of the view that the Australian Radiation Protection
and Nuclear Safety Agency would be the most suitable organisation to assume
responsibility for developing new Australian Standards for EMR. Several
members of staff of this Agency have extensive international experience of
setting standards through their involvement in IAEA, ICRP, ICNIRP, etc. They
can bring the required scientific rigour to the important tasks involved in
setting exposure standards that will protect the Australian population.
Some submissions provided ideas on the
composition of standards setting working groups. For example, Mr Les Dalton
... there should be representation on that committee covering the
whole spectrum of scientific interpretation of the results as they are at the
moment. Also, there should be community representation in order that they can
see the process at first hand. There should also be, I believe, not only
people who are experts in the technical sense but people who come out of the
field of environmental health and perhaps other biological areas. It should be
Mr Dalton believes that it is vital to have
sufficient community representation on a standards-setting committee:
This is where the community has a vital interest in what is
decided. Experts are no more able to judge what risk we should be prepared to
take than is the community itself. Practising a scientific specialty does not
qualify a person to deal with the broader issues associated with the quality of
Other witnesses were opposed to any
representatives from the telecommunications industry being on standards-setting
committees at all:
I believe that industry should be excluded. I do not think that
industry has a role on standards committees; I think industry should be
encouraged to meet whatever standards, from a public health perspective, are
decided are appropriate.
Dr Repacholi informed the Committee that the
World Health Organization does not allow industry to participate in either
standard setting or in health risk assessment. The WHO takes the view that
there cannot be industry representation on standard setting working groups.
There cannot be someone on the working group who is having an influence on
health effects for an industry when they derive benefit from that industry. He
acknowledged, however, that in the United States and Australia a different
approach is followed whereby all stakeholders are represented to set standards
in order to achieve consensus with the standard. This can be seen by the
membership of the Standards Australia TE/7 Committee (see Tables 4.1 and 4.2)
and the ARPANSA Radiation Health Committee Radiofrequency (Exposure Standard)
Working Group (see Table 4.4).
Dr Ken Joyner, from the Mobile Manufacturers
Forum, thought that excluding industry representatives would have a negative
impact on the standards-setting committee:
I think it would be a very negative impact in that the committee
that was set up to, say, look at standards would not be aware of the ease or the
ability of some of these requirements to be implemented, would not be aware of
what the industry has already done, would not be aware of lots of the data that
is already out there. Industry brings lots of experience and knowledge to
these forums, and whether they are there as voting members or expert advisers,
I think it certainly should not diminish the value that they bring to these
Those submissions which were opposed to the
transfer of responsibility to ARPANSA for devising a new Australian standard,
felt that ARPANSA had too close a link to the industry which was pushing for
higher exposure levels:
We are strongly opposed to ARPANSA gaining sole control over the
setting of new Australian Standards. We are not convinced that ARPANSA will represent
Community concerns and Consumer rights properly and fairly.
ARPANSA appears to us as being market driven and we have no
faith whatsoever that they will retain a necessary degree of independence and
impartiality under this current Federal Government.
New Standards should only be set by a team that has equal
representation from all sectors of the community with equal decision making
Mr Dan Dwyer, from the Telecommunications
Officers Association Branch of the Communications Plumbing Electrical Union,
thought that the process used by the Australian Communications Authority to
establish the ARPANSA Working Group was flawed. He believed that ARPANSA was
not the appropriate organisation to devise the Standard because it had taken a
corporate decision to support increased exposures by adopting the ICNIRP
Guidelines, as could be seen from the results of the final Standards Australia
In addition, Mr Dwyer asserted that there is an
apparent bias in the ARPANSA Working Group which stems from the selection
process for Working Group members not being an open process, with an invitation
for inclusion in the group being sent to a chosen few.
Others thought that ARPANSA could make a profit
out of standard setting:
A new standard must be ... set only by a truly independent body,
free from industry pressures and financial self-interests. There is no
merit in transferring this responsibility to the biased Australian Radiation
Protection and Nuclear Safety Agency (ARPANSA). Any organisations who,
directly or indirectly stand to profit from electro-magnetic radiation (like
ARPANSA), will, naturally, try to impose more lenient standards.
Dr Loy, Chief Executive Officer, ARPANSA,
believed that it is necessary to involve people with an industry background on standards
setting bodies, not only because there is a smaller pool of expertise from
which to draw in Australia than the rest of the world, but also because it is
... you can take a pragmatic view that says that, given the level
and the spread of expertise on these issues in this country, if you want to
draw up a standard you are inevitably going to have to involve people who have
some industry background; otherwise the breadth of knowledge is simply not
enough to write the standard. But, having said that, I think you can also say
that it is appropriate that people with industry backgrounds be involved
because they bring to the issue of the preparation of a standard views and
knowledge about how the industry actually works, so that a standard not only
protects the public health but does so in a way that will be effective and also
allow the benefits of the industry to be offered. That is always a balance.
The industry people need to be there to put their side of the case, if you want
to view it that way.
Dr Loy also acknowledged the importance of
community representatives on these bodies:
It is also absolutely important that on the drafting groups
there are people from community backgrounds who have an interest in and
knowledge about the issues but who do not come from an industry background and
who have a community view. That is absolutely important and you should not
draw up these standards without that. The other sine qua non is a process of
wider public involvement. The issue cannot be resolved behind closed doors; it
has to go out to the public widely, and matters that the public bring forward
have to be dealt with and be seen to be dealt with.
Although ARPANSA is a relatively new body,
submissions felt that the history of the Nuclear Safety Bureau effectively
ruled it out as being an independent and impartial standard setting body.
According to Mr Alexander Doull:
New regulatory agencies are often simply made up of the same
people who have been effectively influenced by the very industries they are
supposed to regulate, trading under a new name. ... this change must not proceed
if it has the effect of placing the standard setting process even more securely
into the hands of the sectional interests which generate the radiation in the
first place and further remove the whole process from public interest and
The CSIRO told the Committee:
ARPANSA was charged with helping to write the new Australian
standard and constituted a committee to do that. The CSIRO representative ... concluded
that the committee seemed intent on adopting the ICNIRP guidelines for RF
exposure in Australia without due consideration of all the available evidence
and seemed keen to simply adopt that international standard. He therefore
resigned from the committee. The conclusions: as I said, CSIRO, being a
conservative organisation, would always err on the side of prudence and keep
exposure levels as low as technically, socially and economically feasible.
The Committee notes that in the event of a
dispute or lack of agreement in the ARPANSA working group over the new Standard
including such matters as the inclusion of the precautionary approach, the
Standard would be elevated to the Radiation Health Committee who would then
take the decision.
The Committee Chair is of the view that this
would negate the advantages of having a fair representation of the various
stakeholders on the working group, and it is not persuaded that the TE/7
group’s decision not to support the new Standard should have been effectively
For this reason, the Committee Chair holds that
the process adopted by ARPANSA, particularly with regard to the absence of the
CSIRO, has not been an improvement on that of the Standards Australia TE/7
Committee and is not in the interests of public health.
The Committee Chair remains concerned that
members with industry interests on the ARPANSA working group are, despite
having no voting rights, in a position to influence the discussion.
According to submissions, the major areas of
disagreement between the members of the TE/7 Committee and the reason why the
new standard was not supported, related to the incorporation of a precautionary
approach, and the relaxation of the exposure limits in the proposed Standard.
Mr Dwyer from the CEPU said:
... I oppose adoption of the standard. ... In short the proposed
standard only pays lip service to the precautionary approach and then sets out
to allow even higher exposure levels.
Because of the growing body of scientific
studies that show effects of radiofrequency emissions, as well as the public
apprehension with the safety of the technology, people advocated a
precautionary approach be incorporated in standards.
Dr Repacholi argued that present exposure limits
are set well below levels at which known adverse health effects are possible:
‘[t]his is already an application of a ‘cautionary policy’ and it is important
to recognise it as such’.
The World Health Organization takes the view
that whilst technology standards can be used effectively to implement a
precautionary approach, until technologies to control exposure are well
understood, effective and not unreasonably costly, the precautionary approach
is not appropriate for limiting EMF exposures. The WHO submission says that this
is because exposures to EMF are so common and occur under such a variety of
circumstances that specifying a small number of technologies for controlling
exposures would be impractical.
The Australian Council of Trade Unions (ACTU)
was a member of the TE/7 Committee. It did not support the adoption of AS/NZ
2772.1 for the following reasons:
- there was too much reliance in the proposed standard on the
ICNIRP guidelines, which are based only on thermal effects and make no
allowance for possible non-thermal effects;
- the ICNIRP and its processes have been widely criticised as being
far too secretive;
- the proposal to allow increased exposure from mobile telephones
for no good reason; and
- the downgrading of the precautionary approach, which was needed
in the light of uncertainty regarding the non-thermal risks associated with
The ACTU was also concerned that the proposed
Standard would allow higher levels of radiation to the head of 25 times the
level allowed to the whole body and also, the increase in averaging times from
60 seconds to six minutes. According to the ACTU, these changes would allow
higher peak SARs.
The CSIRO opposed the adoption of the Draft
Standard because it considered it imprudent to increase exposures or averaging
times above those adopted in Australia in 1985.
Mr Dan Dwyer from the Telecommunications
Officers Branch of the Communications Electrical Plumbing Union was convinced
that with the advent of new technologies there will be an increase in
radiofrequency exposure even without allowing an increase in levels in the
Standard. He cites significant new energy sources such as Fixed Radio Access
technology (WLL), high definition television, satellite transmissions and new
mobile phones. In addition:
The profits from these technologies will be enormous. The
benefits will be mostly to multinationals. This has to be balanced against a
risk to public safety.
Whilst many submissions to the inquiry advocated
the inclusion of the Precautionary Principle in the Standard, the effect that
this would have in practice was not made clear. It is reasonable to assume,
however, that people want to be assured that the Government and the
telecommunications industry were working to keep emissions to a minimum and
that developments should proceed with caution.
Dr Repacholi warned against departures from the
ICNIRP so-called science based standards. He said:
... a few countries are now introducing additional ad hoc safety
factors into the science-based standards as a precautionary measure. This
undermines hundreds of millions of dollars worth of science that went into
developing the standards, for no apparent benefit to health.
Dr Repacholi advocated that the precautionary
principle be addressed through a separate policy of voluntary precautionary
These voluntary measures can be through increased research,
encouragement of manufacturers to keep exposures to the minimum needed for the
technology, better risk communication, targeting audiences with honest and
accurate information, public involvement in decision making, and the siting of
facilities to minimise public exposure and concerns. People would generally be
happy with those sorts of measures because it has their involvement and they do
not feel taken out of the equation.
However the Committee Chair considers that, in
view of the internationally accepted definition of the precautionary principle,
public consultation does not constitute a precautionary approach unless it is
followed by mandatory precautionary action.
This voluntary approach has been adopted in
Australia through the Radiofrequency Electromagnetic Energy Program and a Code
of Practice for the Deployment of Radiocommunications Infrastructure, which
will be developed and operate in parallel to the proposed new Standard for
Exposure to Radiofrequency Fields.
The Precautionary Principle
The Precautionary Principle is applied in
circumstances where there is scientific uncertainty. It reflects the need to
take action for a potentially serious risk without awaiting conclusive
An internationally accepted definition of the
Precautionary Principle was summed up in 1992 at the United Nations conference
on Environment and Development in Rio de Janeiro.
Where there are threats of serious or irreparable damage, lack
of full scientific certainty shall not be used as a reason for postponing
cost-effective measures to prevent environmental degradation.
Australia’s Intergovernmental Agreement on the
Environment (IGAE) notes:
Essentially, the Precautionary Principle offers administrators
advice about how to act responsibly in the face of uncertainty and lack of full
scientific knowledge. Under this principle, policy makers are advised to use
great care when authorising resource use where the outcomes of that use cannot
be predicted with confidence, where one or more of the possible outcomes could
have extremely adverse implications for future generations, or where no known
substitutes exist for the resource being used.
The European Commission Communication on the
Precautionary Principle states:
The Precautionary Principle applies where scientific evidence is
insufficient, inconclusive or uncertain – and preliminary scientific evaluation
indicate that there are reasonable grounds for concern that the potentially
dangerous effects on the environment, human, animal or plant health may be
inconsistent with the high level of protection chosen by the EU.
According to the draft Background Document from
the World Health Organization:
The Precautionary Principle may be adopted where there is
“sufficient evidence” that an action or substance is harmful. Various actions
can be taken depending on the strength of evidence, the seriousness of the harm
that may be caused, and the degree of uncertainty about whether the harm is
likely to occur. Possible choices for action range from prevention or
elimination of exposure, to intermediate measures that reduce exposure only
when it is cost-effective to do so, to taking no action unless stronger
evidence is developed that harm is likely to occur.
Prudent Avoidance prescribes taking low-cost
measures to reduce exposure, in the absence of any scientifically justifiable
expectation that the measures would reduce risk. Such measures are generally
framed in terms of voluntary recommendations rather than fixed limits or rules.
As Low As Reasonably Achievable (ALARA)
ALARA is an acronym for As Low As Reasonably
Achievable. It is a policy used to minimise known risks, by keeping exposures
as low as reasonably possible, taking into consideration costs, technology,
benefits to public health and safety and other social and economic concerns.
ALARA is mainly used in the context of ionising radiation protection where
there is no real lower threshold below which effects do not occur.
Dr Repacholi maintains that ALARA is not an
appropriate policy for EMF (either powerline or radiofrequency fields) because
no dose-response relationship has been established at low exposure levels and
no mechanism of action is known that could cause any health problems at low
levels. The Australian Standard 2772—1985 however incorporated the ALARA
principle. According to Dr David Black, this application of the principle has
been much criticised since. Reference to it was removed from the draft
standard in 1998 and, according to Dr Black, it is not a feature of other
Regardless of the names given to the various
precautionary policies, submissions to the inquiry made it clear that people
want to feel that they are not being exposed to harmful amounts of
Those members of the TE/7 Committee who did not
support the draft Standard, argued that the precautionary approach had been
watered down to an unacceptable level. According to Mr Lyle from Standards Australia,
the disagreement arose not over whether a precautionary approach should be
included in the Standard, but about the wording of that precautionary approach:
I think we said that, in the first meeting back in August 1998,
that there was general agreement to use ICNIRP with a yet to be worked out
precautionary approach. It was in the actual words of that precautionary
approach. For the people who voted no, the issue was that it was getting
watered down beyond a level which they thought was actually useful at all. It
was in the wording, rather than whether it be included or not.
Inclusion of precaution in the various standards
Radiofrequency Standards have in the past
included reference to precautionary approaches.
The 1985 Australian Standard included a
precautionary approach in the form of the ALARA Principle. In its Preface it
Moreover it is recommended that the level of all electromagnetic
fields should be kept as low as reasonably achievable.
Clause 2, stated:
Nevertheless, because of the increasing use of equipment
generating radio-frequency radiation and the potential for exposure of
individuals, all possible efforts should be made to keep such exposure as low
as reasonably achievable (ALARA), below the prescribed limits. The overall
economic and social consequences associated with the reduction of exposure to
the individual and the public in general shall be taken into account.
The ALARA Principle is further referred to in
Appendix A (Rationale for the development of the maximum exposure levels for
radio-frequency radiation) of the 1985 Standard.
The 1990 Standard included reference to the
ALARA Principle in its Foreword as well as the recommendation that the level of
all electromagnetic fields should be kept as low as reasonably achievable. Other references to the
principle remained the same as for the 1985 Standard.
The 1998 Interim Standard omitted reference to
the ALARA Principle and instead, referred to the principle of Prudent Avoidance:
While industry should not exceed the limits in this Interim
Standard, exposure to workers and to the public should be kept to the lowest
levels that can be achieved consistent with best international contemporary
practice and cost effective achievement of service objectives. This approach
is consistent with the principle of prudent avoidance. ...
SUBJECT TO THE CONDITIONS OUTLINED ABOVE, EXPOSURES SHALL BE
KEPT TO A MINIMUM.
The CSIRO in its submission quotes its 1994
report The Status of Research of Electromagnetic Radiation: “The problem
is that the standards imply safety thresholds but it is not possible to
identify these on the basis of current equivocal or disparate research”.
Furthermore: “Only when a solid database of independently verified quantified
bioeffects is available will meaningful safety standards be developed and
reassurance of the public be achieved”.
The draft Australian/New Zealand Standard which
was put forward for comment as a replacement for the Interim Standard, included
reference to a precautionary approach, but this was omitted from the ballot
document which was subsequently voted on and for which consensus could not be
The Foreword to the draft contained the words:
This Standard draws extensively on the ICNIRP Guidelines and
emphasises the need for a precautionary approach. ...
So while the basic restrictions in this Standard shall not be
exceeded, the manufacturer/supplier, installer, employer/service provider and
user must be able to demonstrate that exposure to workers and the general
public is being kept to the lowest level that can be achieved, consistent with
best contemporary practices and the cost effective achievement of service
objectives. This is consistent with taking a precautionary approach.
This precautionary approach involves application of best
contemporary practice in achieving service, or process requirements to minimise
incidental RF exposure.
These words were repeated in clause 10 but later
replaced, in the ballot draft with clause 10(d):
Minimising, as appropriate, RF exposure which is unnecessary or
incidental to achievement of service objectives or process requirements,
provided that this can be readily achieved at modest expense.
NOTE: Notwithstanding that ICNIRP
considers that the basic restrictions and reference levels in this Standard
provide adequate protection, it is recognized that community concerns over RF
exposure may be able to be addressed by further minimization of exposure in
accordance with the requirements of Clause 10(d).
ACIF Code of Practice
In response to the failure of the Standards
Australia process to agree to the new Australian Standard, responsibility was
given to ARPANSA to formulate the Australian Standard. In addition, a code of
practice was to be developed in parallel with the ARPANSA Standard by the
Australian Communications Industry Forum (ACIF). According to the Australian
Communications Authority (ACA), ‘[t]his complementary approach is intended to
address both the need for hard exposure limits as well as non-technical matters
that are also of concern to the community’.
The ACIF is the peak telecommunications industry
body in Australia which, according to the Australian Communications Authority,
plays a critical role in assisting the self-regulation of industry through its
work program of industry codes and technical standards.
The ACA informed the Committee that the Code of
Practice will take into account community concerns and draw carriers and
service providers into agreement across the area. It is intended that the Code will be registered by the ACA under section
117 of the Telecommunications Act 1997. Following registration the
obligations on suppliers will become mandatory. The ACA may issue a written
notice to a supplier to direct them to comply with the Code under section 121
and/or impose financial penalties for non-compliance.
The ACIF has established a Radiocommunications
Infrastructure Working Committee to develop the Code of Practice regarding
electromagnetic radiation for the installation and operation of
radiocommunications infrastructure. The Working Committee’s task is to
identify best practice which keeps radiofrequency exposure to the lowest
practical level whilst still delivering a mobile telecommunications service
that is cost effective. Design, risk communication and mitigation, and
operations will be addressed.
Members of the Working Committee come from the
of the ACIF Radiocommunications Infrastructure
Telecommunications Industry Association
Cable & Wireless
Electrical Plumbing Union
Radiation Awareness Network
EMR Alliance of
ARPANSA submitted that the Code of Practice will
be complementary to the Standard and it is needed for the communications
industry to set out how the Standard is met in various settings:
Such a code may also deal with matters such as public
consultation and industry practices taking into account cautionary approaches.
... Additional codes of practice will be developed as required for relevant
industrial, scientific and medical areas.
However the Code requires limited public
consultation processes and will not be prescriptive as to precautionary
measures. Ultimately, this Code gives no assurance that the carriers will not
site installations in sensitive areas.
Low impact facilities
The Committee received numerous submissions
which were concerned with the siting of telecommunications towers and
especially with the provisions of the low-impact facilities determinations. Ms
Gail Darby said:
I feel strongly that communities must be consulted about the
location of all mobile phone towers, including those classified as “low
impact”. All towers must be subject to a development application to the
relevant council. It is unacceptable that current legislation allows
industry to completely ignore state and local planning considerations in
erecting infrastructure. The government’s policy of allowing industry to
duplicate infrastructure systems, power lines or telecommunications, often many
times over, exposes the public to multiple electro magnetic radiation (EMR).
In order to develop Australia’s first mobile
phone networks in the early 1990s, Australia’s telecommunications carriers were
given wide-ranging immunities to town planning laws. With deregulation in
1997, some of these immunities were removed. Guidelines for building visible
network infrastructure were set out in a national code devised and implemented
by the ACA.
New or significant additions to towers and
buildings were made subject to normal town planning approval and the consultative
processes involved. However, under Schedule 3 to the Telecommunications Act
1997, those telephone companies licensed by the ACA as carriers, were
permitted to install a limited range of facilities without seeking state or
territory planning approval. The most common of these are known as low impact
facilities and, according to submissions to this inquiry, have become a cause
of angst for many people in the community. The Warrimoo Citizens Association
Our Association recently had a confrontation with OPTUS, who
without prior consultation, intended erecting Mobile Phone Antennae in the
centre of the Village Precinct. A Public Meeting unanimously condemned this
action and with the support of our Federal Member and unanimous support of the Councillors
from the Blue Mountains City council OPTUS decided to locate in a more isolated
The majority of the citizens of Maleny (Queensland) were upset
about the installation of a Digital Mobile Phone antennae on their water tower,
because of the unknown effects of the digital radiation on human existence.
That water is located in a residential area and only 150 metres from a
The issue can have
broader social concerns in relation to schools and other community bodies that
stand to benefit financially from allowing the placement of a tower on their
grounds or buildings. Mr John Hyde commented:
... we are seeing neighbours
pitted against neighbours, churches against neighbouring pre-school centres, as
telecommunications companies offer building owners money to host these roof-top
facilities ... Under-funded schools, community groups, churches and strata
building owners are tempted by the seemingly high rental a mobile phone company
will offer for you to allow them to erect a tower or transmitters on your roof.
The Telecommunications (Low-impact Facilities)
Determination 1997 lists those types of facilities defined as ‘low impact’.
These are facilities which, because of their size and location, are considered
to have a low visual impact and do not raise significant planning, heritage or
Submissions observed that low impact only refers
to low visual impact and not to the amount of electromagnetic radiation
emitted. The maximum height of a low impact facility is 6.5 metres and the
most commonly installed facility is 5.8 metres high. Overhead cabling and
mobile phone towers (which are generally 25 – 30 metres high) are not
classified as low impact facilities and their installation requires local
council approval. Some other examples of low impact facilities are:
- small radiocommunications dishes and antennae;
- microcell installations;
- in-building coverage installations which are wholly contained and
concealed in a building;
- extensions to towers not exceeding 5 metres in height (providing
there have been no previous extensions to the tower);
- co-located radio facilities where the total volume of the
co-located facilities is no more than 25 per cent greater than the volume of
the original facility or the original infrastructure;
- underground cabling; and
- public payphones.
The Determination also defines where low impact
facilities may be installed based on zoning considerations. For example, a
facility that is deemed low impact in an area zoned rural or industrial may not
be low impact if it is installed in a residential area.
If a facility is to be installed in an
environmentally significant area it cannot be a low impact facility. Areas of
environmental significance are identified in the Determination as the
- an identified property for section 3A of the World Heritage
Properties Conservation Act 1983; [the World Heritage Properties
Conservation Act 1983 has since been repealed]
an identified property (within the meaning of section 3A of the World
Heritage Properties Conservation Act 1983); [the World Heritage
Properties Conservation Act 1983 has since been repealed]
- a place that Australia is required to protect by the terms of a
listed international agreement;
- an area that is legally designated as a reserve for nature
conservation purposes and the principal purpose of the designated reserve is
for nature conservation;
- an area that is legally protected from significant environmental
- an area that is entered in the Register of the National Estate or
the Interim List for that Register;
- an area that is entered in a register relating to heritage
- an area that is legally entered in a register or otherwise
identified as being of significance to Aboriginal persons or Torres Strait
Islanders, in accordance with their traditions.
A carrier authorised under the Act to install a
low impact facility is immune from town planning and environmental laws. When
installing low impact facilities, however, the carriers have certain
- taking all reasonable steps to ensure as little damage and
inconvenience as practicable is caused;
- taking all reasonable steps to ensure that the land is restored
to a condition that is similar to its condition before the installation began;
- acting in accordance with good engineering practice;
- notifying the owner and occupier of the land at least 10 business
days before commencing the installation; and
- taking all reasonable steps to co-locate facilities with the
existing facilities of other carriers and public utilities.
Many community groups have been formed with the
main objective of opposing the installation of a low impact facility. The
major complaints are that these facilities are installed without consultation,
they are placed near sensitive places such as schools, nursing homes and
hospitals, and in residential areas. The Municipal Association of Victoria is
concerned that the low impact facilities determination exemption allows the
carriers to bypass the requirements for high impact facilities:
Councils have reported that Carriers are making minor
modifications to high impact facilities so that they resemble low impact
facilities and don’t require planning approval.
to enjoy the benefits of the low impact facility exemptions must comply with
If low impact facilities are deployed without compliance with the ACIF Code of
Practice after it is registered with the ACA, they will become subject to state and territory town planning
For the Committee’s recommendation relating to
the low impact facility determination, see Chapter 2, Recommendation 2.5.
Dr Repacholi said he recognises that the public
is concerned about mobile telephones and their infrastructure:
I know that the public has tremendous concerns, and I empathise
with those concerns, because the technology has been propagated into people’s
working and living environments without very much consultation. It is a
technology that very few people know much about and, quite reasonably, when
such base stations are placed in schools, parents would ask, ‘Are there any
health effects?’ and if we are in a period of debate about the science then
that is not very reassuring for parents.
According to the Australian Mobile
Telecommunications Association (AMTA), the industry attempts to limit the
amount of mobile phone base stations and to minimise their visual impact:
There are a large number of base stations in the nation. We
recognise that, and the industry is very aware of the visual impact that that
creates. There is a concerted effort by industry to co-locate. In fact, there
is almost a national average of two carriers per site, per tower. Where we
cannot co-locate the industry looks to locate on existing structures such as
water tanks and HV [high voltage] powerlines if we can. Again, it has to fit in
with the honeycomb network and only where necessary do we opt for a new tower
in the area.
The Australian Mobile Telecommunications
Association (AMTA) informed the Committee that it has undertaken three
initiatives in relation to concerns over telecommunications infrastructure: a
national collocation taskforce, a code of conduct and a ‘Know Your Rights’
booklet. AMTA informed the Committee that:
[w]e have become aware that our processes of working with each
other to facilitate collocation have not been as good as they could be. We have
established a national group to review that and in fact established regional
groups in each city to review our processes for collocations to see whether we
can do even better.
The National Collocation Taskforce is designed
to get the carriers to work together so that when there has to be a new tower
in an area, they go to a local council in twos and threes rather than singly.
However, some submissions argue that co-location means an accumulation of
radiofrequency emissions. The Sutherland Shire Council, in its submission,
outlined the following problem with adding low impact facilities to existing
After the installation of the high impact facility - additional
antennae and dishes may be added to the existing structure as ‘low impact’
facilities. This can dramatically change the visual impact and EMR emissions
associated with the structure which can significantly change the conditions
under which approval was granted for the original high impact facility.
With respect to mobile phone base stations, the
Standard requires the aggregate of radiofrequency electromagnetic emissions
coming from all antennas on a single tower, or group of towers, to comply with
the exposure limit set by the Standard.
The second AMTA initiative has been the
development of the Code of Conduct within the Australian Communications
Industry Forum (ACIF), and the third initiative which has been undertaken is to
develop a ‘Know Your Rights’ booklet that is a layperson’s guide to the various
regulations and regulators to assist communities in understanding their rights
in relation to the building of telecommunications infrastructure.
Labelling of phones
One of the issues relating to a precautionary
approach, was a call in the submissions and by witnesses for the labelling of
mobile phones. While the debate about safety of radiofrequency radiation
continues, the public should be alerted to the fact that the phones do emit
radiofrequency radiation and that they should be used with caution.
The Consumers’ Telecommunications Network (CTN),
believes that consumers have the right to make informed choices about the
purchase and usage of mobile phones. It proposes that a mobile phone handset
testing and labelling regime be mandated and extra warnings be implemented in
relation to the sale of mobile phones to children and young people:
Many people have concerns or differing perceived needs relating
to mobile phones. In an open, competitive market, consumers ought to be able
to make informed choices about the product that best suits their needs.
Provision of information about choices does not imply that any one option is a
health risk. Mobile phone handsets should be labelled with warning information
about potential health risks. Information should also be provided about
hands-free kits and other adaptive or ‘protective’ devices intended for use in
conjunction with a mobile phone. 
The CTN suggested that, because many factors
influence the levels of radiofrequency radiation experienced by the user of a
mobile phone, an EME rating scale should be devised and that this EME rating
should be indicated on the handset:
A rating of a number between say, 1 and 10 could be allocated
for each factor and added to give a total score. Thus a handset which is very
good on one factor and not so good in others might obtain a better score than
one which is all round average.
According to the CTN, the phone should be
accompanied by a point of sale leaflet included in the packaging with details
of how the rating is calculated.
The Committee recognises the difficulty in
attempting to compare phones because of the complexity of the technical details
which the consumer is being asked to assess. Depending on the technology used,
there are differences in the output of radiofrequency energy between digital
handsets and analogue units, as well as between GSM and CDMA mobile phones. In
addition, the output of the most modern handset is adaptively determined by the
base station. Consequently, a user’s exposure to radiofrequency energy from a
high-SAR phone in a region of strong base station signal might easily be lower
than from a low-SAR phone in a weak signal area. Although both GSM and CDMA
phones are power controlled, when the GSM phone is operating, it is not power
controlled to the same extent as the CDMA phone.
There are also complexities in using the Special
Absorption Rate (SAR) to distinguish phones. A decision has to be made whether
the peak SAR in the head should be chosen or the 1-gram or 10-gram averaged
SAR. An analogue unit which emits continuous wave energy with an SAR near
regulatory limits needs to be compared with a digital unit, which emits energy
in brief pulses and whose peak SAR might exceed the average SAR from the analogue
unit. When a phone is tested in laboratories to determine its SAR, it is
done so at its maximum power.  The
SAR in its normal operation may be significantly lower than this.
The NATA accredited company Electrical
Compliance Testing Association (ECTA), while supportive of a labelling regime
which provided SAR values for mobile phones, added the following caution:
The benefits of publicly available SAR values will only be
- SAR Testing [is] accredited and
- A standardised test method [is] used.
In August 2000, the Australian Communications
Authority (ACA) announced that it had reached agreement with AMTA and industry
representatives to make information about the maximum emission levels of mobile
phones more readily available. This will be a voluntary scheme but the hope is
that participating manufacturers will gain a competitive advantage in joining
and this will encourage involvement in the scheme.
According to AMTA, participating AMTA members
will make available to consumers information on the SAR of mobile phones. The introduction of this
initiative is dependent on the development of an internationally accepted SAR
testing methodology and suitable testing equipment becoming available. AMTA
expects that resolution of these issues will be some time after April 2001.
The draft proposal for the mobile phone
labelling scheme involves manufacturers placing a label on the outside
packaging of the mobile phones. This label will exhibit an ‘A-tick’ and the
The A-Tick (show A-tick) shows this phone complies with
all current ACA standards, including for exposure to radio frequency energy.
More information is inside this package or at
In addition, participating manufacturers will
include information within the product packaging which reiterates that the
phone complies with the ACA limits and includes general information on SAR, the
standards, as well as the maximum SAR value of the particular phone. This
information may be included as an insert or leaflet to be located with the user
AMTA also informed the Committee that all
manufacturers in AMTA will have a web site that will provide SAR information on
their own individual models.
Whilst the Committee is supportive of any moves
by the industry to inform consumers about its products, the AMTA scheme does
not seem likely to provide Australian consumers with world’s best practice in
labelling schemes. The depiction of the A-tick to show compliance with the
Standard is already an ACA regulatory requirement for the labelling of mobile
Generally, submissions to this inquiry wanted
SAR information to enable consumers to make an informed choice between phones,
and not necessarily to prove compliance with the Standard. If consumers can
easily compare emission levels between phones, market forces will act to
encourage manufacturers to minimise these levels as those phones with lower
outputs may be favoured by consumers. The Committee is of the view that SAR
information should be available at the point of sale and not inserted inside
the packaging only to be discovered after the phone has been purchased.
The Committee Chair recommends the following
points to convey to purchasers of mobile phones:
- because there is a growing body of evidence indicating biological
effects from mobile phones that, as a precautionary measure, it would be
advisable to make fewer and shorter calls and to avoid operating mobile phones
in situations where they need to use maximum power;
- a graphic illustration of the absorption into the head of
- specific absorption rate (SAR) values of particular phones and
the relevance as a measure of exposure; and
- the effect of hands-free kits and shielding devices on limiting
The Committee notes the contrast between the
provision of this information and that proposed by AMTA in its leaflet.
In addition, the Committee concurs with the
recommendations of the Stewart Report:
6.77 We recommend that information on SAR values for mobile
phones must be readily accessible to consumers:
- at the point of sale with
information on the box,
- on leaflets available in stores
giving comparative information on different phones and with explanatory
- as a menu option on the screen of
the phone, and as a label on the phone,
- on a national web site, which
lists the SAR values of different phone types.
Testing for compliance with the Standard
The Australian Communications Authority Standard
(Radiocommunications (Electromagnetic Radiation—Human Exposure) Standard 1999)
is the current Australian Standard with which equipment must comply.
The manufacturer or distributor of portable
devices is responsible for compliance with the Standard. Mobile phones are
designed as either Category A or Category B. Category A phones are low power
devices with little risk of exceeding the mandatory Standard. Manufacturers of
these devices must meet the limits of the Standard but are not required to
demonstrate compliance. However, there may be circumstances where the ACA may
request evidence of compliance.
Category B phones are devices that require
routine evaluation against the Standard according to the test method given in
the Standard. An accredited body must do the test.
Transmitter installations are also divided into
two classes, Category 1 and Category 2. The licensee is responsible for
compliance with the Standard.
Category 1 installations are deemed compliant
with the Standard for reasons such as low power or inaccessibility, but are not
exempt from compliance with the Standard. If there is a reasonable suspicion
that an installation is not compliant, the ACA may require the licensee to
Category 2 installations must be assessed for
compliance with the standard. Self assessment of compliance may be permitted.
Criticism of compliance framework
The Electrical Compliance Testing Association
(ECTA) considered that the ACA audits of compliance documentation are not
rigorous enough to detect non-compliance:
Anecdotal evidence suggests that the audits are simply paper
audits that do not scrutinise the technical content of the reports, which are
the technical basis for EMR compliance.
ECTA asserted that the quality of some of the
EMR testing is of dubious validity, particularly when carried out by the
manufacturers themselves, or by poorly equipped laboratories that do not have
adequate test equipment or sufficient expertise. The reports from such
laboratories may appear valid but careful scrutiny often shows that the EMR
compliance of the subject mobile phone is questionable.
ECTA believed that the major manufacturers of
mobile phones are generally diligent, but it is concerned that the current
system is not transparent to the public:
Our experience is that the top end of town is usually very
diligent in what they do with regard to the quality of their testing and
compliance requirements. I have to emphasise that. However, the closer you get
to the bottom end of the market, the more you will find that the requirements
are often ignored. Sometimes they take shortcuts, sometimes they do not bother
to do anything and sometimes they just fill out a declaration of conformity
without having any basis for that, like a test report. So there is a wide gap
between those that are absolutely diligent and those that are just interested
in commercial realities, in surviving the next day.
Dr Repacholi told the Committee that although he
has had assurances that mobile phones in Australia comply with the Standard, he
would like to see testing of mobile phones:
If you have a standard, you should determine compliance with it.
I do not trust the manufacturers to say, ‘Yes, we’re doing it’.
Testing of shielding devices
The Committee received evidence about devices
which purport to reduce emissions from mobile phones and other electronic
equipment. In some cases, far from reducing emissions, these products can
actually increase them. Mr Chris Zombolas, Vice-President, Electrical
Compliance Testing Association, told the Committee:
... a lot of devices are being sold on the market that claim to
reduce radiation and hence reduce cancer and all those other effects. We have
done a lot of testing for these same suppliers and, in our view, most devices
do not work. Perhaps one or two have some basis but, in general, these devices
will increase the exposure rather than do what they claim - that is, decrease
it. Not only do they increase the exposure but they affect the performance of
the phone, so you get drop-outs happening very often. The battery goes flat
really quickly because it has to raise its power level.
The Committee is concerned that there is no
applicable standard for these devices and nor is there a requirement to test
their effectiveness in reducing exposure. For the Committee’s recommendations
in this regard, see chapter 2, Recommendation 2.4.
Other precautionary measures
Despite the assurances of AMTA that’[p]resent
scientific information does not indicate the need for any special precautions
for the use of mobile phones ...’,
the Committee has heard from numerous individuals who wish to apply
precautionary measures to their mobile phone usage. According to the IEGMP,
they can do this by ensuring that the phone’s antenna is fully extended and
held away from the head; and by using an approved, hands-free set. In addition, the phone
should not be placed against any part of the body when it is turned on. According to the CSIRO,
tests done on phones under worst-case conditions (ie with the antenna touching
the head) have exceeded the recommended limit in standards, and so it is
important that people are made aware of this. The Committee notes newer
phones do not have extendable antennas and that many users keep phones clipped
close to their bodies for lengthy periods.
Standards Australia originally prepared AS 2772
at the request of the communications industry, to cover both occupational and
non-occupational exposure to non-ionising radiation. In the late 1980s it was
agreed that AS 2772.1 would be amended to exclude occupational limits if, and
when, the National Occupational Health and Safety Commission (NOHSC) published
a national standard to cover occupational exposure limits. However the NOHSC
working group which was formed to prepare these standards failed to arrive at a
consensus solution, and so the Standards Australia standard was never amended
in this way.
Telecommunications Network advised the Committee that it had received few
inquiries from employers about the possible health risks to employees who are
required to use mobile phones for their work. The Committee considers that
occupational exposure is potentially a significant health concern.
The Committee received submissions which
criticised both the inclusion of occupational and general standards in the one
document and the fact that the occupational standard allows higher exposure
than does the general population standard.
The Committee heard evidence from OneSteel
Market Mills which manufactures steel pipe, tube and structural profiles.
OneSteel is concerned that its range of magnetic induction heating and welding
units has been caught up by the exposure Standard for radiofrequency fields,
and that this is inappropriate. OneSteel’s concerns extended to the wider
metal-manufacturing industry which it contends is generally unaware of the
likely consequences, or indeed the existence of the exposure standards.
OneSteel advocates that there be a separate standard for the metals industry.
However, the ARPANSA draft standard is intended to
cover the equipment of the metals industry, as Mr Wayne Cornelius from ARPANSA,
informed the Committee:
I see a precautionary approach applying more to the high power
industrial uses of radiofrequency, like RF welders, over which we would like to
see a bit more control as perhaps significant areas where people may right now
be overexposed, as we would see it.
The Community and Public Sector Union advocated
that occupational limits in the Standard should be set at the lower general
public exposure limits.
It cited research showing that workers operating radiofrequency welders, dryers
and induction heaters are being exposed to radiofrequency radiation in excess
of the exposure limits.
The ACTU challenged the assumption that
occupational radiofrequency exposures are ‘controlled’ and that this justifies
higher exposures for workers:
The ACTU would warn against any assumption that occupational
exposures to RFR are currently being adequately identified, let alone
‘controlled’. There is no justification for workers being exposed to a hazard
at levels higher than is allowed for the general public.
notes evidence provided by Dr Hocking in relation to the termination of his
employment as Chief Medical Officer with Telstra. While the Committee does not
wish to comment on this individual case, it supports Dr Hocking’s concern
that Chief Medical Officers in any organisation should be able to investigate
health issues without interference, in accordance with guidelines to ensure
that sound OH&S practices are followed, and employees’ health safeguarded.
The World Health Organization initiative to
harmonise EMF standards is, in part, a response to the fact that many countries
from the former Soviet Union and Eastern bloc countries are now considering new
EMF standards. The Committee has been told that these countries often have
exposure levels many times below those of western countries. Dr Repacholi advised that if
the limits in those countries were actually complied with, no modern technology
would be able to operate.
Globalisation of trade and the rapid
introduction of mobile telecommunications worldwide, have focussed attention on
the differences which exist between standards. Differences between standards
in Eastern European and Western countries can be large. For example, the
levels in the Russian standard are about a thousand times below those in
international standards. As emissions from mobile phones are approximately 100
times the levels in this standard, it becomes obvious that the Russian standard
cannot be complied with, regardless of its exposure levels. The differences between
levels in various countries’ standards raise concerns about their safety and
have led to public anxiety about increasing EMF exposures from the introduction
of new technologies.
Mr Don Maisch told the Committee that the
Russian standards were based on actual effects on workers, whereas the West has
concentrated more on the results from high level animal studies when
establishing its standards.
ARPANSA Working Group Draft Standard
The ARPANSA Working Group released its Standard
(Radiation Protection Standard Maximum exposure levels to radiofrequency fields
— 3kHz to 300GHz) as a draft for public comment on 3 March 2001.
Dr John Loy, Chief Executive Officer, ARPANSA,
emphasised that the draft will be widely available and public comment will be
sought by 11 May 2001. After comment is received, the working group will be
charged with reviewing the public comment and making such further changes to
the draft as it considers warranted. The Radiation Health Committee will
receive a revised draft standard from the working group together with a
description about how each of the public comments has been addressed. The Committee supports this
The Draft Standard determines a number of basic
restrictions. These are limits to exposures expressed in fundamental measures,
and compliance with these limits would be mandatory. The restrictions are
intended to prevent harm at various frequency ranges, arising from electrostimulation
of excitable tissue; whole body heat stress; excessive localised temperature
rise in tissue; annoying or startling auditory effects; and excessive heating
in tissue at or near the body surface.
The limits in the draft standard would prevent local temperature rises of no
more than about 0.1°C, and there would not be any observable core temperature
Dr John Loy, Chief Executive Office, ARPANSA,
informed the Committee that the Draft Standard defines indicative reference
levels from measurable quantities derived from the basic restrictions. These
reference levels are required because the mandatory basic restrictions are
often specified as quantities that are impractical to measure. The reference
levels are intended to be conservatively formulated such that compliance with
them ensures that the basic restrictions are met. The reverse does not
necessarily apply. It could be that there would be circumstances where
reference levels are exceeded but the operator could demonstrate compliance with
the basic restrictions:
In summary, the basic restrictions are the black-letter law; the
reference levels are intended to be measurable quantities. If you fall within
the reference levels, you are clearly in compliance with the basic
The basic restrictions with their corresponding
reference levels appear in the table below:
Draft Standard - Basic restrictions
corresponding reference levels
Corresponding reference levels
Instantaneous spatial peak current density (3
kHz - 10 MHz)
Instantaneous E and/or H (3 kHz - 10 MHz)
and instantaneous contact currents (3 kHz - 10 MHz)
Whole body average SAR (100 kHz - 6 GHz)
Time averaged E and/or H (100 kHz - 6 GHz)
Spatial peak SAR in limbs (100 kHz -
Time averaged E and/or H (100 kHz - 6 GHz)
and/or induced limb currents for the legs and arms (10 MHz -
110 MHz) and contact point currents (100 kHz - 110 MHz)
Spatial peak SAR in head & torso
(100 kHz - 6 GHz)
Time averaged E and/or H (100 kHz - 6 GHz)
Instantaneous spatial peak SAR in head &
torso (10 MHz - 6 GHz)
Instantaneous E, H or power flux density (10
MHz - 6 GHz)
Spatial peak SA in the head (300 MHz - 6
Instantaneous E , H or power flux density (300
MHz - 6 GHz)
Time averaged and instantaneous power flux
density (6 GHz - 300 GHz)
Time averaged and instantaneous E or H (6 GHz -
The basic restrictions are intended to prevent
harm at various frequency ranges as follows:
- electrostimulation of
excitable tissue (3kHz-110 kHz);
- whole body heat stress
- localised temperature rise -
head, torso and limbs (100kHz-6GHz);
- microwave hearing effect
- excessive tissue heating
at/near body surface (6-300GHz).
Dr Loy told the Committee that the Draft
Standard adopts the ICNIRP restrictions and reference levels, but it extends
the ICNIRP Guidelines in several ways. The Draft Standard includes additional
basic restrictions to protect against pulses, and a reduced frequency cut-off
for specific absorption rate and specific absorption from 10 gigahertz to
6 gigahertz, which gives better protection against surface heating. There is
better continuity in the reference levels across the frequency bands, in
addition, it is more conservative at some point frequencies. Finally, the
draft standard has been rigorously defined to work as a standard rather than
simply as guidelines - it provides unambiguous limits for exposures.
Mr Wayne Cornelius, Manager, EMR and Laser and
Optical Radiation Branch, ARPANSA, elaborated on these points for the
... instantaneous spatial peaks are an additional basic
restriction that we have added. It is implied in the ICNIRP guidelines, but it
is something that we have had to identify clearly as being part of the standard
and as a basic restriction. Also spatial peak specific absorption in the head,
as related to very short pulses, was something that was implied in a footnote
to one of the ICNIRP basic restriction tables, but we have drawn it out to
clearly show that that is what is intended.
These additional basic restrictions should
address the concerns expressed by witnesses about averaging times. In the
draft standard it is clear that high bursts of EMR which go above the basic
restrictions will not be permitted by the standard.
Despite claims in submissions and by witnesses
that the ARPANSA Working Group had been directed not to include a precautionary
approach in the new Standard, the draft document does include a form of
precautionary approach. Section 5 of the Standard (Protection - Occupational
and general public exposure) states:
It is generally sensible in achieving service or process
requirements to minimise unnecessary or incidental RF exposure, provided it
does not introduce other risks and can be achieved at modest expense.
In addition, Annex 6 to the Draft Standard
discusses ‘A public health precautionary approach to radiofrequency
radiation’. There are also additional precautions for pregnant workers who
should advise their employer when they become aware of their pregnancy, after
which they must not be exposed to RF fields exceeding the general public
limits. This is to reduce the risk of accidental exposure to RF fields in
excess of the occupational limits.
The very recent release of the Draft Standard
has meant it has not been possible for the Committee Chair to check the
validity of ARPANSA’s assurances.
Having reviewed the evidence, the Committee
Chair does not support the decision to transfer the responsibility for setting
a new Australian Standard for electromagnetic radiation to the Australian
Radiation Protection and Nuclear Safety Agency.
The Committee Chair does not have a view as to
which body should be charged with the responsibility for standard setting but
believes that the process should ensure that the scientific advice which
informs the decision-making should be completely independent of commercial
interests and that consumers and other non-commercial stakeholders should be
involved in the voting process.
The Committee Chair, on reviewing the evidence,
does not support the implementation of standards which are in line with the
ICNIRP Guidelines, but instead recommends that the level of 200 microwatts per
square centimetre in the expired Interim Standard (AS/NZS 2772.1(Int):1998) be
retained in the Australian Standard.
The Committee Chair recommends that the radiofrequency
standard be defined and administered by a process similar to that used by
The Committee Chair recommends that the level of 200
microwatts per square centimetre in the expired Interim Standard (AS/NZS
2772.1(Int):1998) be retained in the Australian Standard.
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