Necessary Questions for Risk Assessment EMF
Transcript of Necessary Questions for Risk Assessment EMF
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Necessary questions for risk assessment EMF & HealthRelevance and completeness of the questions for risk assessment posed to SCENIHR
Introduction
The International EMF Alliance (IEMFA) appreciates that an update of overall risks
assessment on EMF and health is being prepared and that a public consultation is launched.
Comments of the public are explicitly asked on the relevance and completeness of the
questions for risk assessment posed to SCENIHR. IEMFA chooses to place the relevance and
completeness of these questions within the following wider context.
Background
Last decade there is a rising number of warnings for bio-accumulative health hazards of long-term exposure to EMFs. National and international authorities and governments receive
urgent calls from, communities of doctors, scientists and parliaments for a thorough review
of the science basis of the current EMF & Health protection standards. Not only the current
science basis appears questionable. There are mounting indications that also the underlying
risk assessment system isfundamentally inappropriate, as a result of obsolete paradigms and
vested interests. In line, the current protection standards for EMF exposure are increasingly
considered obsolete and inappropriate by the growing international community that is
mentioned above.
Risk assessment system
To enable a better risk assessment and appreciation of the multitude of EMF warnings, and
to stimulate an appropriate basis for an international system for long-term health
protection, any review of the current science basis will therefore be irrelevant and
incomplete, if not first a wider assessment is done. This is a thorough review of the current
risk assessment system EMF & Health. This underlying system of the current science basis is
set up in the last century and consists of a set of ideas, rules and institutions. A thorough
review of this underlying risk assessment system can be done by providing a richer body of
information from more diverse sources, using a wide perspective. Such a multidimensional
review of the appropriateness of the existing risk assessment system may stimulate global
debate and necessary transitions in risk assessment. As such, it may help society to do
substantially better in the future at achieving a responsible balance between EMF
innovations and their hazards.
Relevance of the questions for risk assessment
The International EMF Alliance considers the current questions for risk assessment posed to
SCENIHR, mentioned in the terms of reference therefore largely as irrelevant, if not first the
appropriateness of the underlying risk assessment system itself is assessed. This also counts
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for the currently used risk assessment method. As mentioned it is the underlying system of
the current science basis that increasingly is criticised worldwide. IEMFA therefor
fundamentally disagrees with what is currently presented by established parties as the
scientific credible risks.
Questions for the risk assessment system
To assess the appropriateness of the prevailing risk assessment system, and thereby the
essential fundamentals of risk assessment in any sector, literature indicate that mainly three
overlapping domains of knowledge should be investigated. 1) Gathering a wide body of
information, 2) Clarifying scientific paradigms and 3) Unveiling interests, politics and
perceptions. These three domains should deliver the input for relevant questions for in-
depth risk assessment. The overall assessments of these domains should be done by
integrating the outcomes of many part questions into a coherent, multidimensional whole.
The three domains of deeper risk assessment will get elaborated below
Gathering a wide body of information
To improve our capability of early detection of environmental risks, the European
Environment Agency found, after studying fourteen historical environmental-health cases
were early warnings were interpreted that if more account - scientifically, politically and
economically - is taken of a richer body of information from more diverse sources1. Then
society may do substantially better in the future at achieving a better balance between
innovations and their hazards To know more, for example by searching out blind spots
within disciplines, reaching out to other disciplines, accessing lay and local knowledge to
appraisal early warnings, and taking account of wider social perspectives. Interpretation of
warnings is not a matter of universities alone, but also for other people and institutions
involved in knowledge production. It is about using alternative sources of knowledge and
being open of various types of knowledge and nature of evidence: theoretical, empirical and
even anecdotal Since real world conditions can be very different from theoretical
assumptions, and these differences can have serious consequences2,3
.
Clarifying scientific paradigms
Science can be seen as the combination of theories, methods and facts collected in current
hand and textbooks. In science, there are various communities that start from different
frames of mind. Conceptual frameworks define the paradigm and give it its explanatory
1 Scientific credibility is considered too narrow a criterion for the early detection of new risks, because of the danger of missing early
warnings that only stand the scientific test after evidence of harm is established. Advisory Council for Research on Spatial Planning,Environment and Nature, New risks into the picture?, Ph van Notten, To Learn from Early Warnings, Meta-analysis of Late Lessons from
Early Warnings, Essay Series 202 International EMF Alliance and other public interest NGOs, scientists, members of European parliament and medical doctors, Call for
transparent, impartial and pluralist expert assessment on health risks of non-ionizing electromagnetic fields (EMF). Open letter to
commissioner John DALLI, Health and Consumer Policy, Strasbourg, November 14, 20113 European Environment Agency, Late lessons from early warnings: the precautionary principle 1896 - , Environmental Issue Report No
,
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value. Risk-assessment systems are largely based on underlying paradigms. Paradigms form
a self-reliant explanatory model or conceptual framework of a scientific discipline, shaped by
the communitys background and the context of the historical moment They can also be
described as a thought pattern or model of thinking in a scientific community that generates
the organizing and understanding of reality, or as theoretical framework and set of practices
constituting a more specific way of viewing reality4.
Science does not speak with a common voice, but it is a collection of dominant
paradigms and dissenting opinions. Assessment of (new) risks occurs within an existent
scientific framework of reference5. Based on a meta-analysis of the report Late Lessons from
Early Warnings it is advised to pay attention to dissenting opinions. The above is in line with
the observations of science philosopher Thomas Kuhn. In his book The Structure of Scientific
revolutions6. Kuhn speaks of a revolutionary competition between different scientific
communities, especially in early stages of scientific development. Thus, it takes time for
evidence of scientific discoveries to become accepted, since it must invariably compete with
other evidence.
Unveiling interests, politics and perceptions
In collecting a rich body of information, it also appears important to identify the interests
that might work or suppress research and communication on early warnings on possible
risks. Hulme argues in his book Why We Disagree About Climate Change7, that for a more
fruitful debate, it is better to identify existing frames of mind and recognize them, and not
hide the politics. Solutions arise from the fact that in the debate, people are led by different
frames.
Finally an assessment of the institutions of science is important too. In their bookBending Sciences How Special Interests Corrupt Public Health Research
8, McGarity and
Wagner also point out that the current science institutions are under attack. Not only
science production frequently proves to be cleverly manipulated scientific junk This counts
also for the social perceptions of the outcomes of science The pipeline of sound science
production appears multi-fold surreptitious infiltrated by advocates of interest groups.
Influence science and influence social perceptions.
Needed widening of proposed risk assessmentIndication of additional questions for a realistic risk assessment
In the figure below, different domains of the risk assessment system are indicated. In
essence, for optimal risk assessment pluralistic research is needed, whereby the information
of all these interrelated knowledge parts is brought together to a consistent whole.
4 Kuhn TS, The Structure of Scientific Revolutions, The University of Chicago Press, 1962
5 Advisory Council for Research on Spatial Planning, Environment and Nature. New risks into the picture?. Ph van Notten, To learn from
early warnings, meta-analysis of Late lessons from early warnings, Essay Series 20046 Kuhn Th S. The Structure of Scientific revolutions, . University of Chicago press
7 Hulme M, Why We Disagree About Climate Change; Understanding Controversy, Inaction and Opportunity. University of East Anglia, 2009
8 McGarity ThO, Wagner WE, Bending Science. How Special Interests Corrupt Public Health Research. Harvard UniversityPress, 2008
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Figure 1. Wider knowledge gathering for better risk assessmentRecommended wider gathering of knowledge for better appreciation of early warnings and risk assessment, largely expressedaccording to the EEA 2001, subsequent meta-analysis of the report in 2004, and others. See references elsewhere.
The type of questions to assess the appropriateness of the risk assessment system is divided into
three parts. The questions given are indicative
Using a wide body of information
To what extend:
is risk assessment system open to various types of knowledge?
o
what different types of knowledge are used and do these types have consistent
outcomes?
are diverse sources of knowledge used?o which sources of knowledge?
is both scientific, political and economic information used?
o what background framework of interpretation exists?
is seared for blind spots within disciplines; and reached out to other disciplines?
o which blind spots and links to other disciplines?
is also lay and local knowledge assessed?
o of what groups knowledge is used?
are wider social perspectives taken in to account ?
o which perspectives? are both theoretical, empirical and anecdotal perspectives taken into account?
Et cetera
better risk assessment / appreciation of early warningsInterpretations of science and practice
History
Methods &approaches
Otherinstitutes andpeople
EstablishedInstitutes ofscience
Additionalsciences Local
knowledge
Establishedsciences
Paradigms
Frames ofmind
PerceptionsAnecdotalknowledge
Layknowledge
Books
Dissentingopinions
Wider social
perspective
Interests
Empiricalknowledge
Theoreticalknowledge
Assumptionsand theories
Traditionaldisciplines
Blind spotswithin
disciplines
Politics &economics
Otherdisciplines
Values
Wider credibility appraisal of warnings
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o are these three perspective lying in line?
are real world conditions used?
o do theoretical assumptions and empirical conditions reflect real world?
are both universities and other people and institutes involved?
o what universities and what other people
is attention paid to dissenting opinions?o is there unanimous consensus on the risks of EMFs between different groups?
Paradigms
What is the dominant frame of reference that is used?
What other frames of reference or paradigms are presented?
What dissenting opinions are collected or heard?
Are there indications that dissenting opinions are excluded?
Etcetera
Interests, and perceptions
What special interests are involved, qualitatively and quantitatively?
What parties developed the prevailing frame of reference?
What parties use and prescribe the prevailing frame of reference?
What parties determined the method of research and risk assessment=
Is the risk assessment process transparent?
Can the risk assessment procedure be called impartial?
What institutions are included, what institutions excluded?
What scientists are included, what scientists are excluded?
What non-governmental organisations are included or excluded?
What expert types and groups dominate the risk assessment?
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The International EMF AllianceAlex Swinkels
www.international-emf-alliance.org