The EMF Problem: RF Radiation Governance Without Democratic Risk Assessment.

Part 3. How ICNIRP became the central organising authority for RF-EMF safety standards across much of the world despite the absence of modern environmental public health risk assessment frameworks.

The International Commission on Non-Ionizing Radiation Protection (ICNIRP) is a private, self-selecting international organisation whose exposure guidelines underpin RF-EMF safety standards across much of the world, including Europe, Australia, New Zealand, Canada, the UK, the European Commission, and the Nordic countries.

From what PSGRNZ could determine, none of these jurisdictions, nor the European Commission itself, operates a publicly established, fully operationalised RF-EMF risk-assessment framework comparable to modern environmental toxicology or environmental public health frameworks.

RF-EMF science remains characterised by unresolved questions concerning chronic exposure, cumulative lifetime exposure, developmental vulnerability, and possible non-thermal biological effects. Yet governance systems across these nations continue to reflect late twentieth-century radiation protection paradigms centred primarily on dosimetry, specific absorption rate (SAR), power density calculations, and prevention of established thermal effects.

ICNIRP therefore functions not merely as technical guidance, but as a central organising authority for what is considered scientifically and regulatorily relevant. This has important consequences for which forms of evidence are foregrounded, which disciplines dominate advisory systems, and which uncertainties remain institutionally peripheral.

RF-EMF - A NARROWER (CAPTURED?) FORM OF RISK ASSESSMENT

It is well recognised within science and technology studies that regulatory science is not identical to ‘pure’ science. However, regulatory systems are normally expected to operate through transparent procedural safeguards, including formal evidence-selection rules, evidentiary weighting methodologies, uncertainty characterisation, and defined reassessment processes. In environmental health and toxicology, these procedures are typically embedded within publicly declared risk-assessment frameworks.

When it comes to RF-EMF governance, such frameworks appear largely absent.

These countries do not operate formal environmental public health-style systems in which emerging RF-EMF evidence can be systematically evaluated against broader questions of cumulative exposure, developmental vulnerability, chronic low-dose biological effects, or long-term uncertainty.

Methodologically, ICNIRP’s framework is substantially narrower than contemporary environmental-health risk assessment. ICNIRP is not a regulatory agency and does not operate a legislated risk-assessment system with transparent evidentiary integration frameworks or formal mechanisms for reassessing uncertainty across multiple domains of evidence. Rather, ICNIRP develops exposure guidelines through review and consensus processes focused primarily on established adverse effects and dosimetric evidence.

The modern RF-EMF governance architecture across New Zealand, Australia, Canada, the United Kingdom, and the United States largely emerged during the 1970s–1990s as telecommunications technologies rapidly expanded. These frameworks converged around exposure-compliance models based on SAR thresholds, tissue-heating assumptions, and controlled laboratory exposure conditions. Much of this institutional architecture predates modern systems biology, exposome science, endocrine disruption paradigms, microbiome research, and current understanding of cumulative life-course exposure and chronic multimorbidity.

Scientific findings falling outside the dominant thermal-threshold paradigm, particularly those concerning chronic, low-intensity, or possible non-thermal biological effects, are therefore often treated as peripheral to regulatory decision-making rather than integrated into broader environmental public health assessment models. The resulting governance structure tends to reproduce the assumptions of the prevailing paradigm, reinforcing institutional continuity and the dominance of the status quo.

Despite the rapid expansion of wireless technologies and cumulative population exposure through successive telecommunications roll-outs, there has been no parallel expansion in publicly funded multidisciplinary research capacity examining long-term biological, developmental, environmental, and cumulative exposure questions.

NEW ZEALAND’S WONKY MODEL IS NOT UNUSUAL.

Collectively, Committees with narrow terms of reference, legacy regulations, documents and institutional processes create a form of regulatory path dependency: national authorities and key officials orientate to automatically frame deliberation in terms of SAR modelling, power density thresholds, and prevention of established thermal effects, - while broader environmental public health approaches, such as cumulative lifetime exposure assessment, developmental vulnerability, chronic low-dose biological effects, and uncertainty-based precautionary assessment, remain comparatively peripheral to governance frameworks.

Neither New Zealand, Australia, Canada, the UK the USA, the European Commission or the Nordic countries have a fully operationalised publicly declared framework setting out formal evidence-selection rules, weighting methodologies across mechanistic vs epidemiological evidence, cumulative exposure assessment methodology, uncertainty characterisation procedures, life-course vulnerability analysis, or triggers for reassessment of the underlying thermal-threshold paradigm.

Essentially, these legacy institutional frameworks essentially determine which questions are considered scientifically actionable, which uncertainties count, and which disciplines become authoritative.

U.S.A

A recent paper by Theodora Scarato, characterizes the situation in U.S. policy on wireless technologies and public health protection (Scarato 2025) [i].

The U.S. Federal Communications Commission (FCC) was given regulatory jurisdiction by the U.S. Congress in 1996 over RFR exposure standards setting even though FCC has no in-house expertise regarding health or environmental effects from RFR. FCC is a licensing/engineering entity that relies on other government agencies for guidance on ambient exposures and devices. However, all relevant civilian public health and environmental agencies have been defunded from non ionizing radiation research activities and oversight.

In the United States, responsibility for RF-EMF governance is fragmented across multiple agencies rather than residing within a single dedicated public-health risk assessment body. There is currently no integrated United States agency conducting a comprehensive modern systems-level public health risk assessment programme for RF-EMF comparable to the toxicological frameworks used for environmental chemicals.

Current FCC exposure limits derive largely from 1990s ANSI/IEEE recommendations and are based on dosimetric modelling, specific absorption rate (SAR) thresholds, and prevention of established thermal effects. Methodologically, the framework is primarily engineering and exposure-compliance based, centred on tissue heating thresholds, short-duration exposures, SAR modelling, power density calculations, and device compliance testing.

In practice, the dominant regulatory question is whether RF exposure exceeds levels known to produce established adverse thermal effects, rather than what the cumulative biological consequences may be from chronic low-level real-world exposure across the life course. As a result, the FCC methodology relies heavily on laboratory dosimetry, thermal thresholds, separation-distance testing, phantom models, and controlled exposure assumptions.

AUSTRALIA

As we noted in the previous Substack:

the Australian version, ARPANSA has oversight over the Radiation Health and Safety Advisory Council which is tasked with the identification of emerging issues relating to radiation protection and nuclear safety, and the Radiation Health Committee … legislation which provides the powers for the Australian bodies, as with New Zealand, does not establish this group as a scientific research centre but rather requires findings to align with international best practice.

Australia has a methodology for measuring and regulating exposure against existing thresholds (and here), however lacks a publicly operationalised Australian RF-EMF framework that explicitly sets out: evidence selection rules, inclusion/exclusion criteria, hierarchy and weighting across mechanistic, animal, epidemiological, and clinical evidence, uncertainty treatment, vulnerable population analysis, cumulative exposure assessment, or triggers for precautionary reassessment.

Essentially, there is limited formal operationalisation of cumulative exposure assessment, life-course vulnerability, mechanistic systems biology, uncertainty characterisation, and criteria for reassessing existing thermal-threshold assumptions in response to evolving evidence.

Therefore, although ARPANSA does conduct literature reviews and participates in international scientific review processes. It also refers to: ‘weight of evidence’, ‘systematic review’, and alignment with ICNIRP/WHO evaluations as a way of signalling that a scientific process is being followed.

CANADA

Canada has formal RF exposure limits and technical compliance procedures, but it does not appear to have a publicly articulated, comprehensive methodology for cumulative, life-course, systems-level RF-EMF health risk assessment. Institutional responsibility remains centred within the Health Canada Consumer and Clinical Radiation Protection Bureau under the Environmental and Radiation Health Sciences Directorate. There is no named committee, nor person who is listed as having responsibility for this issue. The dominant framework remains exposure-compliance based, focused on whether exposures remain below limits intended to protect against established adverse effects, rather than on systematically assessing chronic low-level real-world exposure, biological mechanisms, vulnerable populations, and cumulative exposure across the life course.

U.K.

The UK has a more formal public-health advisory structure than the United States, through UKHSA and the Committee on Medical Aspects of Radiation in the Environment (COMARE). The U.K. essentially delegates powers of risk assessment to ICNIRP and enforces compliance with ICNIRP-derived limits.

The UK Health Security Agency (UKHSA) takes the lead on public health matters associated with radiofrequency electromagnetic fields, and has a statutory duty to provide advice to Government on any health effects that may be caused by exposure to EMF. UKHSA’s main advice is that EMF exposure should comply with the Guidelines published by the International Commission for Non-Ionizing Radiation Protection (ICNIRP). (February 9, 2026 Guidance.)

COMARE appears to hold a similar public facing position to New Zealand’s Committee – the committee has representatives from across public agencies, but lacks expert scientists tasked with conducting risk evaluation. The terms of reference do not require that the UK COMARE conduct evidence based reviews, and follow a scientifically rigorous approach, indeed it is likely that the committee is not funded for such work.

The UK lacks a transparent, systems-level public health risk assessment framework designed to evaluate chronic low-level exposure, cumulative exposure, developmental vulnerability, mechanistic biological evidence, and uncertainty across the life course. Ofcom’s role is especially clear: it is not conducting biological risk assessment; it is enforcing compliance with ICNIRP-derived exposure limits.

NORDIC COUNTRIES

Across the Nordic countries, ICNIRP functions not simply as one scientific input among many, but as the central reference architecture for determining what constitutes scientifically recognised risk. Methodologically, Nordic governance still largely remains exposure-compliance based rather than environmental-health risk assessment based.

While Nordic countries do undertake scientific reviews, participate in international expert networks, and periodically reassess the literature through their radiation protection authorities, none of these countries have formally codified an environmental public health RF-EMF risk assessment framework, publicly articulated in the way seen in some chemical, toxicological, or environmental regulatory systems.

Sweden (also here), Norway, Denmark, Finland, and Iceland all rely heavily on the ICNIRP exposure framework, particularly the 1998 and now 2020 guidelines. Their radiation protection agencies consistently frame RF-EMF governance around compliance with ICNIRP exposure limits, dosimetry, SAR modelling, and prevention of established thermal effects.

The Nordic radiation authorities have also issued joint statements explicitly endorsing the view that typical public exposures are well below ICNIRP limits and that there is “no scientific evidence” of adverse effects at ordinary environmental exposure levels. In practice, this places ICNIRP at the centre of regulatory legitimacy across the region.

EUROPEAN GOVERNANCE

European standards and harmonisation processes funnel national governance toward the ICNIRP paradigm. Historically, the pivotal institutional mechanism was the European Council Recommendation 1999/519/EC (and implementation report), which adopted exposure restrictions derived directly from ICNIRP’s thermal and dosimetric framework. ICNIRP limits were subsequently embedded into European technical compliance systems, telecommunications regulation, and product standards through harmonised European standards bodies and EU directives relating to worker and public exposure.

More recently, the ICNIRP 2020 RF guidelines have continued to shape European regulatory updating processes, including reviews undertaken through European Commission scientific committees and technical standard-setting systems. International Telecommunication Union (ITU) regional assessments (E.g. 2021) further show that many European countries align their national frameworks with EU and ICNIRP standards to maintain regulatory harmonisation. The interdependency can be observed when the European Commission reassesses annexes and standards in response to ICNIRP updates.

Europe has scientific review procedures through SCHEER and related EU processes, but it does not appear to have a publicly established, fully operationalised RF-EMF risk-assessment framework comparable to modern environmental toxicology frameworks. For example, The 2023 SCHEER RF opinion considered meta-analyses, systematic reviews, narrative/scope reviews, and some individual papers, and used a weight-of-evidence language. It found no moderate or strong evidence of adverse health effects below the limits in Council Recommendation 1999/519/EC and Directive 2013/35/EU, while acknowledging uncertain evidence for some biological interaction mechanisms.

But that is not the same as a declared framework with formal cumulative lifetime exposure modelling, life-course vulnerability analysis, benchmark-dose modelling, chronic low-dose uncertainty factors, or predefined triggers for reassessing the thermal-threshold paradigm itself.

European Commission processes and updates remain anchored to ICNIRP-derived exposure limits, dosimetry, technical compliance standards, and assessment of whether evidence is strong enough to alter those limits.

THE NEW ZEALAND SITUATION

As we discussed in our last Substack, a Ministry of Health Committee holds the keys to the decision of whether current regulatory standards (controlled by MBIE) are safe, or unsafe and require updating (or not). That Committee broadly lacks expertise in human and environmental health risk assessment and ‘Report to Ministers’ (2015, 2018, 2022) form the bases for decisions on updating are produced without following any scientific process that would be appropriate for a scientific committee when producing a document of relevant scientific and regulatory standing.

No public health or environmental research agency has the funding to research risk.

ICNIRP’s influential position is reinforced when individual governments fail to provide independent funding for science and research into low-level biological effects. New Zealand’s situation is particularly striking. As the previous Substack noted, in 2016 Ministry for Business, Innovation and Employment (MBIE) secured control for the environmental standards for telecommunications. MBIE provides financial support for the expansion of telecommunications towers.

At the same time, MBIE controls science policy and a substantial proportion of New Zealand’s public science funding. Yet it does not fund independent long-term research into the potential human and environmental health risks associated with telecommunications devices, towers, or chronic RF-EMF exposure. Research funding for this area is not ring-fenced by the very same agency that oversees both telecommunications policy and the science funding architecture.

This concentration of regulatory, infrastructure, and science-funding functions weakens the independence expected within democratically accountable public health governance.

The absence of independent funding becomes more significant as telecommunications infrastructure densifies and population exposures increase across the life course. Yet there is no identifiable New Zealand-funded RF-EMF health research programme, and no publicly articulated environmental public health risk assessment framework through which emerging evidence could be systematically evaluated.

Long-term national science programmes, including Science for Technological Innovation, Healthier Lives – He Oranga Hauora, and the Centres of Research Excellence, have not treated RF-EMF as a primary research theme. In practice, this places RF-EMF largely outside the scope of mainstream public-good science funding. Where research has occurred, it has tended to be ad hoc and fragmented rather than part of sustained multidisciplinary programmes involving epidemiology, mechanistic biology, exposure science, developmental vulnerability, or cumulative risk assessment.

New Zealand also lacks a formal methodology or protocol for undertaking comprehensive RF-EMF public health risk assessment. There are no established evidentiary frameworks integrating mechanistic, animal, epidemiological, and exposure data; no cumulative lifetime exposure modelling; and no transparent process for reassessing the assumptions underpinning the prevailing thermal-threshold paradigm.

As a consequence, there are few institutional incentives for scientists to enter the field, build long-term expertise, or challenge prevailing assumptions, particularly where future funding pathways remain dependent on the same institutional structures. Because RF-EMF science is technically complex and highly specialised, mainstream media are also less likely to sustain critical scrutiny in the absence of a visible scientific community capable of enriching public debate. Institutions therefore play a powerful role not only in regulating exposure, but also in shaping which questions are considered scientifically legitimate, fundable, and discussable within the public sphere.

WARNING TO RESEARCHERS – DON’T CHALLENGE THE PARADIGM

A review of the literature for a cohort undertaking long-term New Zealand-based RF-EMF research largely comes up empty. Discrete papers do more to reflect the barriers to research that would contradict the government’s current position on the safety of non-ionising radiofrequency radiation.

An article questioning current research gaps published by one individual (Pockett NZMJ Dec 2018)[ii] was dismissed one year later in an NZMJ piece by prominent professors. At that stage all authors were based at the University of Auckland.

In her 2018 New Zealand Medical Journal paper, Susan Pockett did not simply argue that “more research is needed” in the abstract. Rather, the paper argued that existing RF-EMF regulatory paradigms remain heavily centred on thermal effects and may not adequately account for a growing body of laboratory, mechanistic, and some epidemiological evidence suggesting possible non-thermal biological effects. The paper therefore advanced a precautionary argument: that uncertainty and incomplete knowledge should not automatically be interpreted as evidence of safety, particularly where population exposure is widespread, involuntary, and increasing over time.

At the same time, Pockett also acknowledged that the evidence base remains contested and difficult to interpret. A key concern raised was that modern societies now experience near-ubiquitous RF exposure from multiple sources, making it increasingly difficult to establish truly unexposed comparison populations for long-term epidemiological study. The paper therefore called for substantially more independent and methodologically robust research into chronic low-level real-world exposure, while also questioning whether existing standards frameworks, largely derived from thermal-threshold assumptions, are sufficient to address emerging biological and public health questions.

The response by Professors Elwood and Wood stated that current guidelines are supported by major reviews, and that studies consistently show no evidence of health effects (Elwood and Wood, NZMJ Aug 2019). The Professors strongly criticised Pockett’s ‘selective review’. Although the response paper acknowledged that some studies report biological effects and that ongoing assessment of emerging evidence is necessary, its practical conclusion largely reaffirmed confidence in existing standards and review processes. The paper did not advocate for major expansion of independent long-term RF bioeffects research, cumulative exposure assessment, or broader precautionary public health investigation. As a result, uncertainty was treated primarily as insufficient evidence to alter current standards, rather than as a basis for substantially strengthening multidisciplinary research capacity into chronic low-level RF exposure.

At roughly this time, Elwood was second author on a collaborative paper (Jan 2019[iii]), led by ARPANSA director and ICNIRP serving Vice Chair Ken Karipidis (this is discussed in the previous Substack).

As powerful professors (cancer and biophysics) in a top tier university, the authors soundly dismissed Pockett. The authors were assisted by the central figure on the New Zealand committee, Martin Gledhill, a physicist and expert in monitoring electromagnetic fields and electromagnetic radiation measurement, Gledhill previously led the non-ionising radiation section of the former National Radiation Laboratory within the New Zealand Ministry of Health, and who contracts to the public and private telecommunications sector on monitoring and radiation.

Gledhill’s expertise lay primarily in RF measurement, monitoring, and exposure assessment rather than mechanistic biological or toxicological investigation of chronic low-level RF exposure. Gledhill was not an appropriate source for New Zealand professors to consult with in order to criticise Pockett’s concern for biological effects from low level exposures.

Wood and Elwood could not turn to a New Zealand research cohort researching or producing mechanistic, toxicological, developmental, or biomarker-based studies on RF-EMF non-thermal effects – because such a cohort does not exist.

Pockett also suffered the retraction of a paper in the journal Magnetochemistry, Conflicts of Interest and Misleading Statements in Official Reports about the Health Consequences of Radiofrequency Radiation and Some New Measurements of Exposure Levels. The journal retracted it on the basis that Pockett’s paper contained:

‘no scientific contribution and that Magnetochemistry is not the appropriate forum for this kind of “opinion” publication. Magnetochemistry is devoted to magnetic studies to which the subject of the paper does not relate.’[iv]

(Magnetism and RF-EMF overlap biologically because radiofrequency electromagnetic fields are themselves oscillating electric and magnetic fields. The question is therefore not whether magnetism is involved, it inherently is, but whether the magnetic and electrical components of these fields can interact with biological systems in ways beyond simple tissue heating.)

Although Magnetochemistry characterised the paper as an opinion publication, the claims were referenced and the author was raising concerns about risks for which the scientific evidence base was continuing to evolve. The paper also highlighted broader governance questions regarding the limitations of risk analysis frameworks that require high levels of scientific certainty before precautionary action is considered, as well as the potential influence of industry within standard-setting environments.

These are not implausible concerns. If journals retract papers raising such issues, while the subject matter remains too technical or specialised for meaningful mainstream media discussion, an important question arises: where are scientists and researchers expected to publicly debate emerging concerns regarding uncertainty, methodology, and institutional risk governance?

These broader institutional dynamics provide important context for understanding the reception of Pockett’s work

KEEPING INCONVENIENT SCIENCE OUT OF SCOPE - A LONG HISTORY

Scientists who raise concerns that challenge dominant paradigms, institutional assumptions, commercial interests, or prevailing policy narratives can face significant professional pressures within academia. These pressures are not always overt censorship. More commonly, they operate through softer institutional mechanisms such as reduced funding opportunities, difficulties publishing, exclusion from influential networks, reputational marginalisation, weakened peer relationships, slowed promotion pathways, loss of committee positions, or movement toward less influential institutional roles. In some cases, researchers may become characterised as “controversial,” “activist,” or “outside the mainstream,” which can itself reduce institutional support and career stability.

Importantly, this phenomenon is not unique to any one scientific field. Historians, sociologists, and philosophers of science have long observed that scientific institutions are also social systems shaped by incentives, paradigms, professional networks, funding structures, and reputational dynamics. Dominant frameworks can become self-reinforcing because careers, journals, grants, regulatory systems, and professional authority are often built around prevailing assumptions. This does not mean mainstream science is necessarily wrong; rather, it means that scientific systems can become resistant to disruptive hypotheses, especially where uncertainty remains high and evidence is complex, interdisciplinary, or politically sensitive.

In many respects, this has been Pockett’s journey.

Do you think many scientists would openly advocate for regulation based on chronic, long-term, non-thermal RF-EMF risk when independent funding for this field is limited, the global telecommunications industry is worth hundreds of billions of dollars, mainstream media rarely treats the issue as a legitimate public health concern, and few senior scientists publicly support such positions?

No. Under such conditions, advocating for precautionary regulation, cumulative exposure assessment, or benchmark doses designed to protect vulnerable populations, particularly children, may carry substantial professional, institutional, and reputational risk.

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REFERENCES

[i] Scarato T (2025) U.S. policy on wireless technologies and public health protection: regulatory gaps and proposed reforms. Front. Public Health 13:1677583. doi: 10.3389/fpubh.2025.1677583

[ii] Pockett S. Public health and the radio frequency radiation emitted by cell phone technology, smart meters and WiFi. N Z Med J 2018; 131(1487):97–107.

[iii] Karipidis K, Elwood M, Benke G, Sanagou M, Tjong L & Croft RJ (2019) Mobile phone use and incidence of brain tumour histological types, grading or anatomical location: a population based ecological study. BMJ Open 8: e024489. doi:10.1136/bmjopen-2018-024489

[iv] Pockett, S. RETRACTED: Conflicts of Interest and Misleading Statements in Official Reports about the Health Consequences of Radiofrequency Radiation and Some New Measurements of Exposure Levels. Magnetochemistry 2019, 5, 31.