Invited Lecture 14: From insight to foresight? Some Lessons for 5G from other “new” technologies & agents

Abstract

Brief Biosketch Prof.David GEE graduated in economics and politics and since 1974 has been working at the interface of science and policy-making, within occupational and environmental health, for trade unions, NGOs, and governmental organisations. He is a former Director of Friends of the Earth, in the UK. Between 1995-2012 he worked at the European Environment Agency, latterly as Senior Advisor on Science, Policy and Emerging Issues. Among many other projects eg on eco-tax reform and eco-efficiency, David has been the catalyst, EEA editor and the author of a chapter for the two volumes of Late lessons from early warnings published by the EEA (2001 and 2013). He is now Visiting Fellow at the Institute of Environment, Health, and Societies, Brunel University, London. He is one of the UNESCO/UNITWIN Coordinators under UNESCO Chair Life Sciences (Biophysics, Biotechnology and Environmental Health). Summary of Points for the UNESCO Webinar on 5G & Covid-19, August 7th 2020. The points below are confined to 5G (not Cov-19) and are based on the histories of 27 other “new” technologies, chemicals and other agents over the last 100 or so years, and their now well-established harms, as chronicled in the two volumes of “Late Lessons from Early Warnings” (EEA, 2001, 2013)1. The reports provide insights that can help policymakers to apply foresight with new technologies like 5G to minimise possible harms. There are many (18) striking similarities between RFR/5G and most of the technologies and agents featured in the “Late Lessons” case studies: these are briefly illustrated in Part A below. Some (6) features of 5G that are somewhat novel, and which are also challenging for policymakers are briefly noted in Part B. Some 49 References provide sources of the evidence cited. Part A. Some similarities between 5G and other once “new” technologies/agents. 1) Much hubristic hype surrounded the introduction of the new technology or agent. For example, asbestos was dubbed the “magic mineral”; leaded petrol was the “gift from God”; X-rays were used to provide “the scientific way to fit shoes”; and nuclear power was said to be “too cheap to meter”. This hype served to dull the critical faculties of the relevant regulators and policymakers during the early decades. The early history of X-Rays, another source of radiation exposure to people, is particularly relevant to 5G: “the excitement in the scientific community, and the often inappropriate publicity, ensured that the damage to health, particularly in the long term, was not given any prominence”.2 With 5G, “marketing hype is widespread” (Ref 3). For that, and other reasons, recent advice to Developing Countries' leaders from even Telecommunications experts warns against prematurely joining the “race to 5G”. For example: “Planning for 5G is a series of complicated choices as there are issues at the levels of creating ecosystems to support it; unproven business models, with claims for applications which may not be financially viable yet; plus confusion over choices of radio spectrum; and selection of equipment suppliers; even potential issues over public health, as well as the real level of industrial and consumer demand beyond the hype”. The emphasis here is on the importance of making balanced strategic choices, by identifying the basic issues, in a 'realpolitik' fashion - including “why embrace 5G at all”.3 2) There was a failure to systematically and independently scrutinise the claimed benefits and costs (and the non-quantifiable pros and cons) of the new technology/agents. In most of the EEA case studies both the costs of the “new” technology and its later harms were often underestimated, whilst the benefits were often overestimated4, usually because most of the cost/benefit analyses (CBAs) were done by the technology promoters themselves. 5G is costing much more than 2-4G; it needs substantial government support; and its estimated costs are very likely to escalate, partly because it is a more complicated system to roll out than 2-4 G. Another “late Lesson” comes from the relatively simple roll-out of smart meters which already demonstrates the ease with which forecasted costs escalate and benefits diminish. The UK National Audit Office report on “Smart Meters”5 observed that the cost of installing smart meters was already 50 % higher by 2017 than the BEIS Department's initial forecast; and that “it is currently uncertain whether the industry cost savings forecast by the Department will materialise”. One key and unresolved cost/con of 5G, which is acknowledged by some in the telecommunications industry, is the increased security risk. This is “much more complicated to manage…the challenge is amplified by vertical 5G use-cases such as connected cars and health care”….“5G's shared infrastructure has the potential for mass failure across multiple networks”.6 3) There was an early closing down of promising alternative technologies, such as alcohol-based petrol instead of leaded petrol. Alternatives for 5G include wired systems; photonics; and visible light communications, plus more exploitation of the relatively recent 3/4G systems. 4) There was a gross imbalance between research on developing/promoting the agent/technology and research on anticipating and reducing potential harm to people and environments from the agent/technology. For example, the BSE case shows that relevant hazard identification research was overly delayed7. For Information Technologies an EEA analysis of EU research funding 2007-20138 clearly demonstrated this heavy bias towards research on technology promotion (99.95%) compared to hazard anticipation (0.05%). There is very little research available on 4 and 5G. And the EEA case studies demonstrate that “no evidence of harm is not evidence of no harm” because the relevant research has not been done. 5) There was a failure to ensure independent research into health/environmental effects. Many reviews of research in the tobacco, lead, pharmaceutical, climate change and EMF industries show a strong funding bias whereby research financed by the relevant industry tends to not find harm whereas independent research does.9 Independent research also helps to minimise the impact of the “manufactured doubt” about hazards, pioneered by the tobacco industry, and widely used by other technology promoters10. 6) There was a failure of relevant scientists to acknowledge what they do not know11; to properly understand and embrace knowledge from other relevant disciplines; to fully acknowledge the limitations of their models of realities and of real (not just estimated or proxy) exposures; and to be transparent about their paradigms, values and other choices made in their often divergent evaluations of the evidence12. This sometimes provides impressions of certainty which are misplaced13. Misunderstanding and competition between disciplines characterised many case studies e.g. between medics and vets (BSE); and epidemiologists and physicists (radiation), making it more difficult for policymakers to take robust, comprehensive, and timely decisions. Within the EMF field, there are essentially two basic paradigms competing for the current “truth”: one based on thermal tissue heating (held by ICNIRP and thereby accepted by many regulatory agents) and the other on non-thermal cell signalling effects. The current exposure limits are based essentially on the thermal paradigm. And as children are more sensitive to RF from mobile phones they “will bear the health costs of this paradigm war”.14 These differences in paradigms, as well as the conflicts of interests of some scientists with close links to the telecommunications industries and yet who sit on EMF evidence review committees (such as the International Commission on Non-ionizing Radiation Protection (ICNIRP)15, and the UK's Advisory Group on Non-ionizing Radiation16) together with the “intellectual biases” of scientists, help to explain the widely divergent evaluations of the “same” evidence17. A recent Italian appeal court case, which awarded compensation for an acoustic neuroma “probably” caused by RF from a mobile phone, dismissed the ICNIRP based evidence submitted by the defence as being “less reliable” than the more independent expertise submitted by the claimant.18 7) There was a failure of scientists to be transparent about the paradigms, assumptions, judgements and values used in academic science and their evaluations of scientific evidence in regulatory science. 8) There was a failure of scientists and policymakers to appreciate complex and variable realities; multi-causality; and the likelihood of inconsistent scientific results arising from such complexity. The exposure patterns from 5G are likely to be especially complex, varying, and yet poorly understood, or researched. The first recommendation in the EU paper on 5G (Ref 3, p6) was to “increase long term R&D efforts to understand multiple propagation unknowns e.g. measuring and controlling RF-EMF exposures with MIMO at mmWave frequencies”. 9) There was an inability to account for real-world conditions which characterized many case studies: this led to the risks of harm being underestimated e.g. BSE; MTBE; PCBs. With EMF/RF the real world of complex and very variable exposures involving different field intensities; pulsing; modulation; frequency variations; polarization etc. is often ignored in laboratory experiments19 where simulated rather than real mobile phone exposures are often used: the latter are often more damaging to DNA.20 10) There was a failure by scientists and policymakers to understand the difference between the high strength of evidence needed to establish robust scientific knowledge and the case-specific appropriate strength of evidence needed to justify precautionary and timely policy actions to reduce or minimise harm from existing agents, in the face of scientific uncertainty, nescience (ignorance), and expert disagreements. The idea of an appropriate strength of evidence for timely action has been legally established in much national legislation, beginning with the “foresight”, or precautionary, a principle in Germany in the 1980s; and thence into the EU and many international treaties21. Current examples of the case-specific strengths of evidence justifying policy actions range from a “scientific suspicion of risk”, justifying a temporary ban on a widely used chemical in Sweden, to the “balance of evidence” (1995) and the “very high confidence” (2007) in human-induced climate change established by the UN Climate Change scientists.22 Waiting for “convincing” (ICNIRP and many regulatory agencies) evidence of harm before governments take action guarantees that there will be harm. 11) There was a failure by policymakers to take precautionary action on early and later warnings of impending harms. Plausible scientific early warnings were ignored, denied, suppressed, and distorted23 for decades24 in most of the case studies, resulting in much harm and many costs to companies, victims, the environment, and taxpayers Significant and plausible early warnings about the possible harms from EMF have been available since the 1950s, and especially since the epidemiological studies from 1999-2011, which identified the glioma (brain) and acoustic neuroma cancer risks to some long term users of mobile phones25. These human studies led the EEA to issue three early warnings on RF and head cancer, in 2007, 2009, and 201126, and to WHO/IARC classified RF as a “possible” carcinogen in 201127. Since then the evidence has strengthened, particularly from two large scale animal studies (from the US National Toxicology Program28 and the Italian Ramazzini institute29) which both found similar cancers, including the brain, at relevant human exposure levels. Consequently, the IARC Advisory Committee recently gave EMF/RF a “high priority” for a re-evaluation of the cancer evidence since the first IARC evaluation on 201130. Many independent EMF scientists31 in Europe, the USA, Russia, and Asia now consider that there are at least “reasonable grounds of concern”32 about the health and environmental effects of EMF to justify applying the precautionary principle to RF exposures.33 12) In 7 of the 34 EEA case studies, the “Foresight (precautionary) Principle was used to justify timely action. E.g. on antibiotics in animal feed (Sweden 1985 and EU 1999); on TBT in marine paint (France 1984); on CFCs (EU 1980), on neonicotinoid pesticides (France 1999, 2004 and EU 2013), and hormones in beef (EU 1985). In all cases, the evidence for harm has increased since those timely decisions. 13) There was a failure to protect “early warning ”scientists who were often severely harassed for bringing “inconvenient truths” to the public and governments. E.g. Hendersen & Needleman (leaded petrol); Selikoff (asbestos), Grandjean (mercury); Putzei & Chapella (GMOs); Schneider (Climate Change.); Alice Stewart (X-rays). And for EMF, Henry Lai, Lennart Hardell and others34. 14) All of the 27 established false-negative case studies demonstrated that: the eventual harm always expanded beyond what was first identified (e.g. for tobacco, from lung cancer to many cancers, heart disease and foetal toxicity; and for ionising radiations, from skin cancers to leukaemia and to all cancers); exposures to the harmful agent always expanded beyond what was first observed (e.g. from laboratories to factories to families to consumers and to local, regional and sometimes global environments; and the “safe” exposure limits always came down with expanding knowledge of harm, often to no known threshold of safety, as with lead, ionising radiations, and all carcinogens. For example, the “known and established” risks for ionising radiations increased 4/5 times between the ICRP evaluations of 1977 and 1990, with associated reductions in the exposure limits. The existing exposure limits for EMF set by ICNIRP and copied by most regulatory agencies are based essentially on short term thermal tissue heating effects and do not protect against long term effects, such as cancer. Ex ICNIRP35 and IEEE scientists36, as well as 388 doctors and EMF scientists,37 are now calling for lower, more appropriate exposure limits for EMF. 15) A failure to manage the “latency lacuna” whereby evidence of chronic harm necessarily comes years/decades after much technical change in the exposure conditions which generated the harm. This allows the assertion that “today's” exposures are different from those of 10-30 years ago, and are therefore “safe”, an assertion that cannot be disproved for another 10-30 years38. This is particularly relevant to the fast-moving telecommunications industry. 16) There was a failure to include the emerging costs of harm (“economic externalities”) into the market price of the technology. Consequently, alternatives were kept out of their markets for decades by these low and subsidised, prices. And the large external costs were largely met eventually by victims and taxpayers.39 For 2-5G mobile phone manufacturers and network operators there seems to be little if any liability insurance, nor “anticipatory insurance” to pay for any future harm: for example, the “precautionary assurance bonds or funds” used in the banking, mining, and oil exploration sectors40. This ensures that current and future taxpayers will meet most of any external costs of EMF/5G, such as damage to health, wildlife, ecosystems, planetary observations41, security and human rights. Consequently, Swiss Re42 and others43 suggest there will be an upturn in future liability claims against the telecommunications industries. A recent Danish legal opinion concludes that there is “a clear and substantial causal link” between the exposure of humans and animals to radiofrequency electromagnetic radiation and a range of damaging effects to both groups”.44 17) There was a failure to provide adequate insurance systems so that the large costs of harms to people and environments were paid by victims, taxpayers, and nature: rarely by the polluter. 18) There was a failure to involve the public in helping to choose their technological/chemical futures via “responsible Innovation” and to avoid toxic trespass: this often resulted in the meltdown of public trust in scientists and governments and to the rise of ultimately successful community and NGO activities against the “new” technology. “Responsible innovation” is characterised by a “transparent interactive process by which societal actors and innovators become mutually responsive to each other regarding the ethical acceptability, sustainability, and social desirability of the innovation process and its marketable products”44. Not involving the public more in the deployment of 5G and in the development of responsible and safer products is likely to further diminish trust in both governments and corporations, especially given the apparently enhanced security and privacy risks of 5G which are acknowledged by some in the telecommunications industry45. Part B Some novel and challenging features of 5G The weak Business case for 5G: “there are unanswered questions over what 5g actually is, what is it for, whether it is safe, whether it offers good value for money, or whether anyone will be prepared to pay for it”46. 5G is much more expensive than 2-4G, requiring significant government support. EMF exposures to children and other sensitive groups will greatly increase in total and in complexity Harm to birds, insects and other species is likely47; as is space pollution48. Security and privacy will be seriously compromised Human rights will be seriously compromised.49 Public trust and localism will be damaged, as there are strong legal barriers to democratic involvement in the siting of antenna masts and other telecoms installations. D. Gee