Tuesday 16 July 2019

ARPANSA standards are indefensible and dangerous


In Australia, ionising and non-ionising radiation exposure standards as set by ARPANSA and regulated by ACMA. ARPANSA was created under the ARPANS Act 1998, with the stated objective:
Object of Act: The object of this Act is to protect the health and safety of people, and to protect the environment, from the harmful effects of radiation.
Wikipedia defines safety as:
Safety is the state of being "safe" (from French sauf), the condition of being protected from harm or other non-desirable outcomes. Safety can also refer to the control of recognized hazards in order to achieve an acceptable level of risk.
So, safety is the control of recognised hazards. Let's have a look at some definitions from SafeWork Australia:
  • Hazard - A situation or thing that has the potential to harm a person.
  • Risk - The possibility that harm (death, injury or illness) might occur when exposed to a hazard. [emphasis mine]
  • Carcinogen - A substance or mixture that causes or is suspected of causing cancer.
RF radiation, like mobile phone radiation, wifi and so on, is a hazard. It is not inert. Therefore it is regulated and safety standard is applied.
In 2011, IARC classified as Class 2b 'possibly carcinogenic' "Radiofrequency electromagnetic fields, such as, but not limited to, those associated with wireless phones", saying
“The conclusion means that there could be some risk…”
Note: the NTP study 2018 did provide 'clear evidence' for the carcinogenicity of mobile phone radiation but the study was not designed to provide dosimetry or exposure data. Heat is not classified by IARC, therefore the risk of cancer must be driven by non-thermal effects. But from the ARPANSA standard, "published in 2002 and replublished [nice spelling mistake!] in May 2016" states:
"The possibility of carcinogenic effects of exposure to RF fields has received considerable attention in the last 20 years. Studies have examined the possibility that RF energy may cause DNA damage or influence tumour promotion. The balance of evidence suggests that exposure to RF fields is not mutagenic and therefore unlikely to act as an initiator or promoter of carcinogenesis (IEGMP 2000)."
Therefore the ARPANSA standard is proven obsolete since it fails to acknowledge any developments in the RF hazard research over the past 20 years, the IARC classification in 2011 or any progress in the development of risk management procedures since this section was drafted on or before 2000.
The stated objective of the ARPANS Act, interpreted under modern Risk management best practices, would necessitate a Precautionary approach under conditions of uncertainty. ARPANSA do not take a Precautionary approach to setting exposure standards since it only considers thermal effects and deliberately and explicitly disregards consideration of non-thermal effects, despite the stated presence of uncertainty. Clearly ARPANSA is failing in its obligations under the ARPANS Act. The CEO must be fired and a Royal Commission held on it's conduct. Further, due to its egregious failings, ARPANSA has clearly disqualified itself as an authority on RF safety.

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