INTERNATIONAL ASSOCIATION OF FIRE FIGHTERS
DIVISION OF OCCUPATIONAL HEALTH, SAFETY AND MEDICINE
Position on the Health Effects from Radio Frequency/Microwave (RF/MW) Radiation in Fire Department Facilities from Base Stations for Antennas and Towers for the Conduction of Cell Phone Transmissions
The International Association of Fire Fighters’ position on locating cell towers commercial wireless infrastructure on fire department facilities, as adopted by its membership in August 2004 (1), is that the IAFF oppose the use of fire stations as base stations for towers and/or antennas for the conduction of cell phone transmissions until a study with the highest scientific merit and integrity on health effects of exposure to low-intensity RF/MW radiation is conducted and it is proven that such sitings are not hazardous to the health of our members.
Further, the IAFF is investigating funding for a U.S. and Canadian study that would characterize exposures from RF/MW radiation in fire houses with and without cellular antennae, and examine the health status of the fire fighters as a function of their assignment in exposed or unexposed fire houses. Specifically, there is concern for the effects of radio frequency radiation on the central nervous system (CNS) and the immune system, as well as other metabolic effects observed in preliminary studies.
It is the belief of some international governments and regulatory bodies and of the wireless telecommunications industry that no consistent increases in health risk exist from exposure to RF/MW radiation unless the intensity of the radiation is sufficient to heat body tissue. However, it is important to note that these positions are based on non-continuous exposures to the general public to low intensity RF/MW radiation emitted from wireless telecommunications base stations. Furthermore, most studies that are the basis of this position are at least five years old and generally look at the safety of the phone itself. IAFF members are concerned about the effects of living directly under these antenna base stations for a considerable stationary period of time and on a daily basis. There are established biological effects from exposure to low-level RF/MW radiation. Such biological effects are recognized as markers of adverse health effects when they arise from exposure to toxic chemicals for example. The IAFF’s efforts will attempt to establish whether there is a correlation between such biological effects and a health risk to fire fighters and emergency medical personnel due to the siting of cell phone antennas and base stations at fire stations and facilities where they work.
Critical questions concerning the health effects and safety of RF/MW radiation remain. Accordingly, should we allow exposure of our fire fighters and emergency medical personnel to this radiation to continue for the next twenty years when there is ongoing controversy over many aspects of RF/MW health effects? While no one disagrees that serious health hazards occur when living cells in the body are heated, as happens with high intensity RF/MW exposure (just like in a microwave oven), scientists are currently investigating the health hazards of low intensity RF/MW exposure. Low intensity RF/MW exposure is exposure which does not raise the temperature of the living cells in the body.
Additionally, a National Institute of Environmental Health Sciences panel designated power frequency electromagnetic fields (ELF/EMF) as “possible human carcinogens.” (2) In March 2002 The International Association on Research on Cancer of the World Health Organization also assigned this designation to ELF/EMF in Volume 80 of its IARC Monographs on the Evaluation of Carcinogenic Risks to Humans.(3)
Fixed antennas used for wireless telecommunications are referred to as cellular base stations, cell stations, PCS (“Personal Communications Service”) stations or telephone transmission towers. These base stations consist of antennas and electronic equipment. Because the antennas need to be high in the air, they are often located on towers, poles, water tanks, or rooftops. Typical heights for freestanding base station towers are 50-200 feet.
Some base stations use antennas that look like poles, 10 to 15 feet in length, that are referred to as “omni-directional” antennas. These types of antennas are usually found in rural areas. In urban and suburban areas, wireless providers now more commonly use panel or sector antennas for their base stations. These antennas consist of rectangular panels, about 1 by 4 feet in dimension. The antennas are usually arranged in three groups of three antennas each. One antenna in each group is used to transmit signals to wireless phones, and the other two antennas in each group are used to receive signals from wireless phones.
At any base station site, the amount of RF/MW radiation produced depends on the number of radio channels (transmitters) per antenna and the power of each transmitter. Typically, 21 channels per antenna sector are available. For a typical cell site using sector antennas, each of the three transmitting antennas could be connected to up to 21 transmitters for a total of 63 transmitters. When omni-directional antennas are used, a cellular base station could theoretically use up to 96 transmitters. Base stations used for PCS communications generally require fewer transmitters than those used for cellular radio transmissions, since PCS carriers usually have a higher density of base station antenna sites.
The electromagnetic RF/MW radiation transmitted from base station antennas travel toward the horizon in relatively narrow paths. The individual pattern for a single array of sector antennas is wedge-shaped, like a piece of pie. Cellular and PCS base stations in the United States are required to comply with limits for exposure recommended by expert organizations and endorsed by government agencies responsible for health and safety. When cellular and PCS antennas are mounted on rooftops, RF/MW radiation levels on that roof or on others near by would be greater than those typically encountered on the ground.
The telecommunications industry claims cellular antennas are safe because the RF/MW radiation they produce is too weak to cause heating, i.e., a “thermal effect.” They point to “safety standards” from groups such as ANSI/IEEE or ICNIRP to support their claims. But these groups have explicitly stated that their claims of “safe RF/MW radiation exposure is harmless” rest on the fact that it is too weak to produce a rise in body temperature, a “thermal effect.”(4)
There is a large body of internationally accepted scientific evidence which points to the existence of non-thermal effects of RF/MW radiation. The issue at the present time is not whether such evidence exists, but rather what weight to give it.
Internationally acknowledged experts in the field of RF/MW radiation research have shown that RF/MW transmissions of the type used in digital cellular antennas and phones can have critical effects on cell cultures, animals, and people in laboratories and have also found epidemiological evidence (studies of communities, not in the laboratory) of serious health effects at “non-thermal levels,” where the intensity of the RF/MW radiation was too low to cause heating. They have found:
- Increased cell growth of brain cancer cells (5)
- A doubling of the rate of lymphoma in mice (6)
- Changes in tumor growth in rats (7)
- An increased number of tumors in rats (8)
- Increased single- and double-strand breaks in DNA, our genetic material (9)
- 2 to 4 times as many cancers in Polish soldiers exposed to RF (10)
- More childhood leukemia in children exposed to RF (11)
- Changes in sleep patterns and REM type sleep (12)
- Headaches caused by RF/MW radiation exposure (13)
- Neurologic changes (14) including:
- Changes in the blood-brain-barrier (15)
- Changes in cellular morphology (including cell death) (16)
- Changes in neural electrophysiology (EEG) (17)
- Changes in neurotransmitters (which affect motivation and pain perception) (18)
- Metabolic changes (of calcium ions, for instance) (19)
- Cytogenetic effects (which can affect cancer, Alzheimer’s, neurodegenerative diseases) (20)
- Decreased memory, attention, and slower reaction time in school children (21)
- Retarded learning in rats indicating a deficit in spatial “working memory” (22)
- Increased blood pressure in healthy men(23)
- Damage to eye cells when combined with commonly used glaucoma medications (24)
Many national and international organizations have recognized the need to define the true risk of low intensity, non-thermal RF/MW radiation exposure, calling for intensive scientific investigation to answer the open questions. These include:
- The World Health Organization, noting reports of “cancer, reduced fertility, memory loss, and adverse changes in the behavior and development of children.” (25)
- The U. S. Food and Drug Administration (FDA) (26)
- The International Agency for Research on Cancer (IARC) (27)
- The Swedish Work Environmental Fund(28)
- The National Cancer Institute (NCI) (29)
- The European Commission (EC) (30)
- New Zealand’s Ministry of Health (31)
- National Health and Medical Research Council of Australia(32)
- Commonwealth Scientific Industrial Research Organization of Australia (CSIRO) (33)
- The Royal Society of Canada expert group report prepared for Health Canada (34)
- European Union’s REFLEX Project (Risk Evaluation of Potential Environmental Hazards from Low Frequency Electromagnetic Field Exposure Using Sensitive in vitro Methods)(35)
- The Independent Group on Electromagnetic Fields of the Swedish Radiation Protection Board (SSI)(36)
- The United Kingdom’s National Radiological Protection Board (NRPB)(37)
- The EMF-Team Finland’s Helsinki Appeal 2005 (38)
Non-thermal effects are recognized by experts on RF/MW radiation and health to be potential health hazards. Safe levels of RF/MW exposure for these low intensity, non-thermal effects have not yet been established.
The FDA has explicitly rejected claims that cellular phones are “safe.” (39)
The Environmental Protection Agency (EPA) has stated repeatedly that the current (ANSI/IEEE) RF/MW safety standards protect only against thermal effects. (40)
Many scientists and physicians question the safety of exposure to RF/MW radiation. The CSIRO study, for example, notes that there are no clear cutoff levels at which low intensity RF/MW exposure has no effect, and that the results of ongoing studies will take years to analyze. (41)
Internationally, researchers and physicians have issued statements that biological effects from low-intensity RF/MW radiation exposure are scientifically established:
· The 1998 Vienna-EMF Resolution (42)
· The 2000 Salzburg Resolution on Mobile Telecommunication Base Stations (43)
· The 2002 Catania Resolution (44)
· The 2002 Freiburger Appeal (45)
· The 2004 Report of the European Union’s REFLEX Project (Risk Evaluation of Potential Environmental Hazards from Low Frequency Electromagnetic Field Exposure Using Sensitive in vitro Methods) (46)
· The 2004 Second Annual Report from Sweden’s Radiation Protection Board (SSI) Independent Expert Group on Electromagnetic Fields Recent Research on Mobile Telephony and Health Risks (47)
· Mobile Phones and Health 2004: Report by the Board of NRPB (The UK’s National Radiological Protection Board) (48)
The county of Palm Beach, Florida, the City of Los Angeles, California, and the country of New Zealand have all prohibited cell phone base stations and antennas near schools due to safety concerns. The British Columbia Confederation of Parent Advisory Councils [BCCPAC] passed a resolution in 2003 banning cellular antennae from schools and school grounds. This organization is comparable to the Parent Teachers Association (PTA) in the United States. The resolution was directed to B.C. Ministry of Education, B.C. Ministry of Children and Family Development, B.C. School Trustees Association, and B.C. Association of Municipalities.
US Government Information
In the United States, the Federal Communications Commission (FCC) has used safety guidelines for RF/MW radiation environmental exposure since 1985.
The FCC guidelines for human exposure to RF/MW radiation are derived from the recommendations of two organizations, the National Council on Radiation Protection and Measurements (NCRP) and the Institute of Electrical and Electronics Engineers (IEEE). In both cases, the recommendations were developed by scientific and engineering experts drawn from industry, government, and academia after extensive reviews of the scientific literature related to the biological effects of RF/MW radiation.
Many countries in Europe and elsewhere use exposure guidelines developed by the International Commission on Non-Ionizing Radiation Protection (ICNIRP). The ICNIRP safety limits are generally similar to those of the NCRP and IEEE, with a few exceptions. For example, ICNIRP recommends different exposure levels in the lower and upper frequency ranges and for localized exposure from certain products such as hand-held wireless telephones. Currently, the World Health Organization is working to provide a framework for international harmonization of RF/MW radiation safety standards.
In order to affirm conformity to standards regarding heating of tissue, measurements are time averaged over 0.1 hours [6 minutes]. This method eliminates any spikes in the readings. Computer power bars have surge protectors to prevent damage to computers. Fire fighters and emergency medical personnel do not!
The NCRP, IEEE, and ICNIRP all have identified a whole-body Specific Absorption Rate (SAR) value of 4 watts per kilogram (4 W/kg) as a threshold level of exposure at which harmful biological thermal effects due to tissue heating may occur. Exposure guidelines in terms of field strength, power density and localized SAR were then derived from this threshold value. In addition, the NCRP, IEEE, and ICNIRP guidelines vary depending on the frequency of the RF/MW radiation exposure. This is due to the finding that whole-body human absorption of RF/MW radiation varies with the frequency of the RF signal. The most restrictive limits on whole-body exposure are in the frequency range of 30-300 MHz where the human body absorbs RF/MW energy most efficiently. For products that only expose part of the body, such as wireless phones, exposure limits in terms of SAR only are specified.
Similarly, the exposure limits used by the FCC are expressed in terms of SAR, electric and magnetic field strength, and power density for transmitters operating at frequencies from 300 kHz to 100 GHz. The specific values can be found in two FCC bulletins, OET Bulletins 56 and 65.
OET Bulletin 56, “Questions and Answers about Biological Effects and Potential Hazards of Radiofrequency Electromagnetic Fields” was designed to provide factual information to the public by answering some of the most commonly asked questions. It includes the latest information on FCC guidelines for human exposure to RF/MW radiation. Further information and a downloadable version of Bulletin 56 can be found at: http://new.iaff.org/HS/PDF/FCC%20Bulletin%2056%20-%20EMF.pdf
OET Bulletin 65, “Evaluating Compliance With FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields” was prepared to provide assistance in determining whether proposed or existing transmitting facilities, operations or devices comply with limits for human exposure to RF/MW radiation adopted by the Federal Communications Commission (FCC). Further information and a downloadable version of Bulletin 65 can be found at: http://new.iaff.org/HS/PDF/FCC%20Bulletin%2065%20-%20Cell%20Towers.pdf
The FCC authorizes and licenses products, transmitters, and facilities that generate RF and microwave radiation. It has jurisdiction over all transmitting services in the U.S. except those specifically operated by the Federal Government. Under the National Environmental Policy Act of 1969 (NEPA), the FCC has certain responsibilities to consider whether its actions will significantly affect the quality of the human environment. Therefore, FCC approval and licensing of transmitters and facilities must be evaluated for significant impact on the environment. Human exposure to RF radiation emitted by FCC-regulated transmitters is one of several factors that must be considered in such environmental evaluations. In 1996, the FCC revised its guidelines for RF/MW radiation exposure as a result of a multi-year proceeding and as required by the Telecommunications Act of 1996.
For further information and answers to questions about the safety of RF/MW radiation from transmitters and facilities regulated by the FCC go to http://www.fcc.gov/oet/rfsafety/rf-faqs.html.
Canadian Government Information
Industry Canada is the organization that sets regulatory requirements for electromagnetic spectrum management and radio equipment in Canada. Industry Canada establishes standards for equipment certification and, as part of these standards, developed RSS-102, which specifies permissible radiofrequency RF/MW radiation levels. For this purpose, Industry Canada adopted the limits outlined in Health Canada’s Safety-Code 6, which is a guideline document for limiting RF exposure. A downloadable version of “RSS-102 – Evaluation Procedure for Mobile and Portable Radio Transmitters with respect to Health Canada’s Safety Code 6 for Exposure of Humans to Radio Frequency Fields”, as well as additional information can be found at: http://new.iaff.org/HS/PDF/Safety%20Code%206.pdf
Safety Code 6 specifies the requirements for the use of radiation emitting devices. This Code replaces the previous Safety Code 6 – EHD-TR-160. A downloadable version of “Limits of Human Exposure to Radiofrequency Electromagnetic Fields in the Frequency Range from 3 kHz TO 300 GHz – Safety Code 6”, as well as further detailed information can be found at .http://new.iaff.org/HS/PDF/Non-Ionizing%20Radiation%20Volume%2080.pdf
US and Canadian Legal Issues
Although some local and state governments have enacted rules and regulations about human exposure to RF/MW radiation in the past, the Telecommunications Act of 1996 requires the United States Federal Government to control human exposure to RF/MW radiation. In particular, Section 704 of the Act states that, “No State or local government or instrumentality thereof may regulate the placement, construction, and modification of personal wireless service facilities on the basis of the environmental effects of radio frequency emissions to the extent that such facilities comply with the Commission’s regulations concerning such emissions.” Further information on federal authority and FCC policy is available in a fact sheet from the FCC’s Wireless Telecommunications Bureau at www.fcc.gov/wtb.
In a recent opinion filed by Senior Circuit Judge Stephen F. Williams, No. 03-1336 EMR Network v. Federal Communications Commission and United States of America, the Court upheld the FCC’s decision not to initiate an inquiry on the need to revise its regulations to address non-thermal effects of radiofrequency (RF) radiation from the facilities and products subject to FCC regulation as EMR Network had requested in its September 2001 Petition for Inquiry.
At the request of the EMR Network, the EMR Policy Institute provided legal and research support for this appeal. On January 13, 2005, a Petition for Rehearing en banc by the full panel of judges at the DC Circuit Court of Appeals was filed. Briefs, background documents and the DC Circuit decision are found at: http://www.emrpolicy.org/litigation/case_law/index.htm.
The Toronto Medical Officer of Health for the Toronto Board of Health recommended to Health Canada that public exposure limits for RF/MW radiation be made 100 times stricter; however the recommendation was not allowed, since, as in the US, only the Canadian federal government can regulate RF/MW radiation exposure level.
World Health Organization Efforts
In 1996, the World Health Organization (WHO) established the International EMF Project to review the scientific literature and work towards resolution of health concerns over the use of RF/MW technology. WHO maintains a Web site that provides addition information on this project and about RF/MW biological effects and research. For further information go to http://www.who.int/peh-emf/en/.
For decades, the International Association of Fire Fighters has been directly involved in protecting and promoting the health and safety of our membership. However, we simply don’t know at this time what the possible health consequences of long-termexposure to low-intensity RF/MW radiation of the type used by the cell phone base stations and antennas will be. No one knows–the data just aren’t there. The chairman of the International Commission on Non-Ionizing Radiation Protection ICNIRP), one of the leading international organizations which formulated the current RF/MW radiation exposure guidelines, has stated that the guidelines include “no consideration regarding prudent avoidance” for health effects for which evidence is less than conclusive (49)
Again, fire department facilities, where fire fighters and emergency response personnel live and work are not the proper place for a technology which could endanger their health and safety
The only reasonable and responsible course is to conduct a study of the highest scientific merit and integrity on the RF/MW radiation health effects to our membership and, in the interim, oppose the use of fire stations as base stations for towers and/or antennas for the conduction of cell phone transmissions until it is proven that such sitings are not hazardous to the health of our members.