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The scientific basis for statements made in the Ministry of Health's 5G Factsheet

Michael Vaughan made this Official Information request to Ministry of Health

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From: Michael Vaughan

Dear Ministry of Health,

I am concerned about the inaccurate and misleading nature of statements made in the Ministry of Health's 'Factsheet' on 5G.

The information I am requesting is as follows:

1) Who was/were the person/people responsible for researching the material included in the Factsheet and for writing the Factsheet?
2) Regarding the statement '5G is simply a new application of radio technology'.....while this is an accurate statement in that 5G is indeed a new application of radio technology, I am concerned that there is a strong IMPLICATION that it's very similar to 3G and 4G. In reality, the higher 'millimetre wave' frequencies are very different from the 3G and 4G frequencies in their technical characteristics - so different, in fact, that tens of thousands of transmitters would have to be brought into people's neighbourhoods to roll out a functional 5G network. I would like to know why this is not acknowledged in the MOH Factsheet rather than a deliberate implication that it's just a slightly different version of 3G and 4G.
3) Regarding the statement "Existing research on the possible health effects of radiofrequency (RF) fields applies as much to 5G as to any other radio system in use"...........I would like to know on what basis scientifically is this statement made?
The behaviour and characteristics of the higher frequencies proposed for 5G differ markedly from 3G and 4G as mentioned above. The large body of existing research (tens of thousands of studies) relates to the lower frequencies used for 3G, 4G and wi-fi. The research on health effects of these frequencies (which is very mixed and open to differing opinions - hence the vast discrepancy in Safety Standards adopted in countries around the globe) CANNOT be ASSUMED to apply to the health effects of higher frequencies with markedly different characteristics. There is nothing scientific about this assumption. Therefore, I request an explanation of the logic and science used to make the above statement in the Ministry of Health's 'Factsheet'. Please note that a response along the lines of 'the higher frequencies proposed for 5G are non-ionising radiation just like 3G and 4G, so they can be viewed in the same way' would be TOTALLY UNACCEPTABLE. That would be like saying that a Suzuki Swift and a Ferrari can be treated as the same because they are both cars. Just as a Suzuki Swift and a Ferrari are very different in their behaviour and performance even though they are both cars, the behaviour, performance and health effects of 5G cannot be assumed to be the same as 3G and 4G just because they fall under the broad heading of 'non-ionising radiation'.

Yours faithfully,

Michael Vaughan

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Kia ora

Thank you for your email dated 30 November 2019 requesting the following
information under the Official Information Act 1982:

The Ministry's reference number for your request is: H201910257.

As required under the Act we will endeavour to respond to your request no
later than 20 January 2019, being 20 working days after the day your
request was received.  

If we are unable to respond to your request within this time frame, we
will notify you of an extension of that time frame.

If you have any queries related to this request, please do not hesitate to
get in touch.
 
Nga mihi

OIA Services
Government Services
Office of the Director-General
Ministry of Health
E: [email address]

[1]http://www.health.govt.nz

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From: Michael Vaughan

Dear Ministry of Health,

I have not yet received a response to my request for information regarding 'The Scientific Basis for Statements made in the Ministry of Health's 5G Factsheet'. I understand that, by law, a response should have been made by December 31, 2019. The inclusion of misleading and inaccurate statements on a government department's website is a serious matter. I request your prompt attention to my request for information.

Yours faithfully,

Michael Vaughan

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Mr Rodgers left an annotation ()

The MoH date of 20 January is correct. There is a working day "holiday" between 25 December and 15 January.

Section 2 of the OIA:
"working day means any day of the week other than—
...
(b) a day in the period commencing with 25 December in any year and ending with 15 January in the following year.

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Kia ora Mr Vaughan

Please find attached a letter regarding your request for official
information.

Ngā mihi

OIA Services
Government Services
Office of the Director-General
Ministry of Health
E: [email address]

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From: Michael Vaughan

Dear Ministry of Health,

In your response, you say that "the existing research database includes studies that have looked at the effects of millimetre waves. These have formed the basis for the exposure standards covering these frequencies."

As you well know, the research on health effects of millimetre waves is extremely small compared to the vast number of studies on the existing 3G. 4G and wi-fi frequencies. Your Interagency Committee has found reason to disregard or ignore literally thousands of studies showing biological effects of these existing frequencies at levels way below the NZ Safety Standards. The usual reason given is that the studies have not been sufficiently large-scale and rigorous in their design (even the USD20+ million National Toxicity Programme study seems to have been largely disregarded).

Yet, your Interagency Committee and the M.O.H. seem happy to form conclusions about the safety of Millimetre wave frequencies on the basis of a small group of studies, most of which are small-scale and have not been replicated. Interesting.

For example, on what basis has the M.O.H. concluded that existing Safety Standards will adequately protect the New Zealand public from eye damage, given that the energy of the higher frequencies will primarily be absorbed by the skin and eyes? Please provide references for studies considered to be adequate in their size and design and which have also been replicated.

The skin is not just an overcoat - it is our largest organ with many functions. One of the functions is regulation of the immune system. On what basis has the M.O.H concluded that existing Safety Standards will adequately protect the New Zealand public from disruption to immune system regulation? Please provide references for studies considered to be adequate in their size and design and which have been replicated.

I request that you do not answer these questions with a link to your research data-base. I have already followed the link provided. What I am asking for is specific information about the particular studies considered by the M.O.H. and its Interagency Committee to fulfil the criteria for 'robust scientific research' as mentioned above.

Yours faithfully,

Michael Vaughan

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Kia ora

Thank you for your email dated 07 March 2020 requesting the following
information under the Official Information Act 1982:

In your response, you say that "the existing research database includes
studies that have looked at the effects of millimetre waves. These have
formed the basis for the exposure standards covering these frequencies."

As you well know, the research on health effects of millimetre waves is
extremely small compared to the vast number of studies on the existing 3G.
4G and wi-fi frequencies. Your Interagency Committee has found reason to
disregard or ignore literally thousands of studies showing biological
effects of these existing frequencies at levels way below the NZ Safety
Standards. The usual reason given is that the studies have not been
sufficiently large-scale and rigorous in their design (even the USD20+
million National Toxicity Programme study seems to have been largely
disregarded).

Yet, your Interagency Committee and the M.O.H. seem happy to form
conclusions about the safety of Millimetre wave frequencies on the basis
of a small group of studies, most of which are small-scale and have not
been replicated. Interesting.

For example, on what basis has the M.O.H. concluded that existing Safety
Standards will adequately protect the New Zealand public from eye damage,
given that the energy of the higher frequencies will primarily be absorbed
by the skin and eyes? Please provide references for studies considered to
be adequate in their size and design and which have also been replicated.

The skin is not just an overcoat - it is our largest organ with many
functions. One of the functions is regulation of the immune system. On
what basis has the M.O.H concluded that existing Safety Standards will
adequately protect the New Zealand public from disruption to immune system
regulation? Please provide references for studies considered to be
adequate in their size and design and which have been replicated.

I request that you do not answer these questions with a link to your
research data-base. I have already followed the link provided. What I am
asking for is specific information about the particular studies considered
by the M.O.H. and its Interagency Committee to fulfil the criteria for
'robust scientific research' as mentioned above.

The Ministry's reference number for your request is: H202001261.

As required under the Act we will endeavour to respond to your request no
later than 03 April 2020, being 20 working days after the day your request
was received.  

If we are unable to respond to your request within this time frame, we
will notify you of an extension of that time frame.

If you have any queries related to this request, please do not hesitate to
get in touch.
 
Nga mihi

OIA Services
Government Services
Office of the Director-General
Ministry of Health
E: [email address]

[1]http://www.health.govt.nz

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1. http://www.health.govt.nz/

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Ministry of Health


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Kia ora Michael

Please find attached a letter regarding your request for official
information.

For ease, listed below are the links provided in the response letter:

* [1]https://www.health.govt.nz/our-work/envi...
* [2]https://www.fda.gov/media/135043/download
* [3]https://www.icnirp.org/cms/upload/public...
* [4]https://pubmed.ncbi.nlm.nih.gov/31540320/
* [5]https://s3-us-west-2.amazonaws.com/ieees...

Ngā mihi

OIA Services
Government Services
Office of the Director-General
Ministry of Health
E: [email address]

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References

Visible links
1. https://www.health.govt.nz/our-work/envi...
2. https://www.fda.gov/media/135043/download
3. https://www.icnirp.org/cms/upload/public...
4. https://pubmed.ncbi.nlm.nih.gov/31540320/
5. https://s3-us-west-2.amazonaws.com/ieees...

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From: Michael Vaughan

Dear Ministry of Health,

In response to my concern about the lack of quality, replicated scientific studies on health effects of millimetre waves, you provided me with a link to a review of research. The review is summarised as follows:

"The introduction of the fifth generation (5G) of wireless communication will increase the number of high-frequency-powered base stations and other devices. The question is if such higher frequencies (in this review, 6-100 GHz, millimeter waves, MMW) can have a health impact. This review analyzed 94 relevant publications performing in vivo or in vitro investigations. Each study was characterized for: study type (in vivo, in vitro), biological material (species, cell type, etc.), biological endpoint, exposure (frequency, exposure duration, power density), results, and certain quality criteria. Eighty percent of the in vivo studies showed responses to exposure, while 58% of the in vitro studies demonstrated effects. The responses affected all biological endpoints studied. There was no consistent relationship between power density, exposure duration, or frequency, and exposure effects. The available studies do not provide adequate and sufficient information for a meaningful safety assessment, or for the question about non-thermal effects. There is a need for research regarding local heat developments on small surfaces, e.g., skin or the eye, and on any environmental impact. Our quality analysis shows that for future studies to be useful for safety assessment, design and implementation need to be significantly improved. There is a need for research regarding local heat developments on small surfaces, e.g., skin or the eye, and on any environmental impact. Our quality analysis shows that for future studies to be useful for safety assessment, design and implementation need to be significantly improved."

I draw your attention to the following statements:
(a) "Eighty percent of the in vivo studies showed responses to exposure, while 58% of the in vitro studies demonstrated effects."
(b) "The available studies do not provide adequate and sufficient information for a meaningful safety assessment, or for the question about non-thermal effects. There is a need for research regarding local heat developments on small surfaces, e.g., skin or the eye, and on any environmental impact. Our quality analysis shows that for future studies to be useful for safety assessment, design and implementation need to be significantly improved.

These statements clearly illustrate the exact point that I was making, i.e. that the existing studies on millimetre waves CANNOT be considered anywhere near sufficient for conclusions to be drawn about safety....and there is a clear need for further research. Which begs the question: Given the lack of quality research into safety, what is the justification for the Ministry of Health's assurances about the safety of 5G and its apparent support for rolling out this technology?

I also draw your attention to point number 3 in my original OIA request concerning the Ministry of Health's assertion that the large body of existing research (pertaining to existing 3G, 4G and wi-fi frequencies) can be applied to the much higher 5G frequencies (which have very different characteristics and interaction with the human body, including almost total absorption by the first few millimetres of the skin and eyes). I have asked for the scientific basis for this assumption and this has still not been forthcoming.

I request that these points are addressed clearly and specifically and that your answers do not include various links which do not address these specific points directly.

Thank you.

Yours faithfully,

Michael Vaughan

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Ministry of Health


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Kia ora Michael

Thank you for your request for official information received 3 May 2020
for:

"In response to my concern about the lack of quality, replicated
scientific studies on health effects of millimetre waves, you provided me
with a link to a review of research. The review is summarised as follows:

"The introduction of the fifth generation (5G) of wireless communication
will increase the number of high-frequency-powered base stations and other
devices. The question is if such higher frequencies (in this review, 6-100
GHz, millimeter waves, MMW) can have a health impact. This review analyzed
94 relevant publications performing in vivo or in vitro investigations.
Each study was characterized for: study type (in vivo, in vitro),
biological material (species, cell type, etc.), biological endpoint,
exposure (frequency, exposure duration, power density), results, and
certain quality criteria. Eighty percent of the in vivo studies showed
responses to exposure, while 58% of the in vitro studies demonstrated
effects. The responses affected all biological endpoints studied. There
was no consistent relationship between power density, exposure duration,
or frequency, and exposure effects. The available studies do not provide
adequate and sufficient information for a meaningful safety assessment, or
for the question about non-thermal effects. There is a need for research
regarding local heat developments on small surfaces, e.g., skin or the
eye, and on any environmental impact. Our quality analysis shows that for
future studies to be useful for safety assessment, design and
implementation need to be significantly improved. There is a need for
research regarding local heat developments on small surfaces, e.g., skin
or the eye, and on any environmental impact. Our quality analysis shows
that for future studies to be useful for safety assessment, design and
implementation need to be significantly improved."

I draw your attention to the following statements:
(a) "Eighty percent of the in vivo studies showed responses to exposure,
while 58% of the in vitro studies demonstrated effects."
(b) "The available studies do not provide adequate and sufficient
information for a meaningful safety assessment, or for the question about
non-thermal effects. There is a need for research regarding local heat
developments on small surfaces, e.g., skin or the eye, and on any
environmental impact. Our quality analysis shows that for future studies
to be useful for safety assessment, design and implementation need to be
significantly improved.

These statements clearly illustrate the exact point that I was making,
i.e. that the existing studies on millimetre waves CANNOT be considered
anywhere near sufficient for conclusions to be drawn about safety....and
there is a clear need for further research. Which begs the question: Given
the lack of quality research into safety, what is the justification for
the Ministry of Health's assurances about the safety of 5G and its
apparent support for rolling out this technology?

I also draw your attention to point number 3 in my original OIA request
concerning the Ministry of Health's assertion that the large body of
existing research (pertaining to existing 3G, 4G and wi-fi frequencies)
can be applied to the much higher 5G frequencies (which have very
different characteristics and interaction with the human body, including
almost total absorption by the first few millimetres of the skin and
eyes).  I have asked for the scientific basis for this assumption and this
has still not been forthcoming.

I request that these points are addressed clearly and specifically and
that your answers do not include various links which do not address these
specific points directly."

The Ministry's reference number for your request is: H202002822.

As required under the Official Information Act 1982 we will endeavour to
respond to your request no later than 29 May 2020, being 20 working days
after the day your request was received.  

If we are unable to respond to your request within this time frame, we
will notify you of an extension of that time frame.

If you have any queries related to this request, please do not hesitate to
get in touch.

Please note, the Ministry has diverted significant resources to support
the Government's response to COVID-19. This may impact on our ability to
respond to your request. If you would like to reconsider or refine your
current request, this may enable us to respond more quickly. You can
notify us of any changes to your request by replying to this email.

Ngā mihi

OIA Services
Government Services
Office of the Director-General
Ministry of Health
E: [email address]

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Kia ora Michael

Please find attached a letter regarding your request for official
information.

Ngā mihi

OIA Services
Government Services
Office of the Director-General
Ministry of Health
E: [email address]

show quoted sections

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From: Michael Vaughan

Dear Ministry of Health,

I find the reply by Deborah Woodley to be totally unsatisfactory for two main reasons:
1) Her reply completely ignored my request for an explanation of the statement on the M.O.H. website, i.e. the claim that the large body of existing research (pertaining to existing 3G, 4G and wi-fi frequencies) can be applied to the much higher 5G millimetre wave frequencies (which have very different characteristics and interaction with the human body). The '5G and Health' section on the M.O.H. website claims that "existing research on the possible health effects of radio frequency (RF) fields applies as much to 5G as to any other radio system in use." I ask again for the scientific basis for this assumption (my first question requiring a SPECIFIC response please). I find it amazing that the results of studies of different frequencies would be ASSUMED to be the same, given that the characteristics of the frequencies are substantially different,
2) Her reply represented a classic case of 'cherry picking' a few studies to support her argument that "current knowledge provides no persuasive evidence that the limits currently used in New Zealand do not provide protection". I note the clever insertion of the word 'persuasive' as I'm sure that Deborah Woodley is aware that there are studies finding adverse health effects, some of which are included at this link: https://ehtrust.org/scientific-research-...
Deborah Woodley's conclusion (no doubt formed with the advice of the Interagency Committee for Health Effects of Non-Ionising Radiation, with a history of membership involving clear Conflicts of Interest)) differs from the view of world-renowned expert on electromagnetic frequencies, Dr. Darius Leszczynski. Please note that Dr. Leszczynski has expertise and qualifications far in excess of any member of the aforementioned Committee. He has worked with the World Health Organisation (WHO) and the International Agency for Research on Cancer (IARC) in this field. Dr. Leszczynski has recently completed a review to be published in the journal 'Reviews on Environmental Health' (see link: https://betweenrockandhardplace.wordpres.... He concludes "there is an urgent need for research on the biological and health effects of mm-waves because, using the currently available evidence on skin effects, the claims that “we know skin and human health will not be affected” as well as the claims that “we know skin and human health will be affected” are premature assumptions that lack sufficient scientific basis."
Given that this highly-qualified, world-renowned expert has conducted a review of the millimetre wave research on health effects and come to this conclusion, I contend that the Ministry of Health should apply the 'Precautionary Approach', discontinue support for the roll-out of 5G and withdraw statements
giving premature assurances of safety.
My second question, therefore, is as follows: On what basis can the Ministry of Health support the roll-out of 5G and give the New Zealand public assurances of safety, given that expert opinion is clearly stating that insufficient research has been done to make any conclusions about either adverse health effects or safety?

Yours faithfully,

Michael Vaughan

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Kia ora Michael

Thank you for your email.

The Ministry's reasoning for making the statement that existing
research on the possible health effects of radio frequency (RF) fields
applies as much to 5G (including 5G at millimetre wave frequencies) as to
any other radio system in use has already been explained to you several
times, most recently on 29 May 2020. The Ministry agrees that it is wise
to pay attention to the views of experts, and you have been referred to
the expert reviews from health and scientific bodies that guide the
Ministry's policies and advice in this area. This expert opinion does not
undermine the basis of existing safety standards.   

Your requests are now deemed closed.  If you are unsatisfied with the
Ministry's response, you may wish to approach the Ombudsman.

This request is now deemed closed. If you are unsatisfied with the
Ministry's response, you may wish to approach the Ombudsman.

Ngâ mihi

OIA Services
Government Services
Office of the Director-General
Ministry of Health
E: [email address]

From:        "Michael Vaughan"
<[FOI #11761 email]>
To:        "OIA/LGOIMA requests at Ministry of Health"
<[Ministry of Health request email]>,
Date:        24/06/2020 07:52 p.m.
Subject:        Re: Response to your request for official information
(ref: H202002822)

--------------------------------------------------------------------------

Dear Ministry of Health,

I find the reply by Deborah Woodley to be totally unsatisfactory for two
main reasons:
1) Her reply completely ignored my request for an explanation of the
statement on the M.O.H. website, i.e. the claim that the large body of
existing research (pertaining to existing 3G, 4G and wi-fi frequencies)
can be applied to the much higher 5G millimetre wave frequencies (which
have very different characteristics and interaction with the human body).
The '5G and Health' section on the M.O.H. website claims that "existing
research on the possible health effects of radio frequency (RF) fields
applies as much to 5G as to any other radio system in use." I ask again
for the scientific basis for this assumption (my first question requiring
a SPECIFIC response please). I find it amazing that the results of studies
of different frequencies would be ASSUMED to be the same, given that the
characteristics of the frequencies are substantially different,
2) Her reply represented a classic case of 'cherry picking' a few studies
to support her argument that "current knowledge provides no persuasive
evidence that the limits currently used in New Zealand do not provide
protection".  I note the clever insertion of the word 'persuasive' as I'm
sure that Deborah Woodley is aware that there are studies finding adverse
health effects, some of which are included at this link:
[1]https://scanmail.trustwave.com/?c=15517&...
Deborah Woodley's conclusion (no doubt formed with the advice of the
Interagency Committee for Health Effects of Non-Ionising Radiation, with a
history of membership involving clear Conflicts of Interest)) differs from
the view of world-renowned expert on electromagnetic frequencies, Dr.
Darius Leszczynski. Please note that Dr. Leszczynski has expertise and
qualifications far in excess of any member of the aforementioned
Committee. He has worked with the World Health Organisation (WHO) and the
International Agency for Research on Cancer (IARC) in this field. Dr.
Leszczynski has recently completed a review to be published in the journal
'Reviews on Environmental Health' (see link:
[2]https://scanmail.trustwave.com/?c=15517&...
He concludes "there is an urgent need for research on the biological and
health effects of mm-waves because, using the currently available evidence
on skin effects, the claims that “we know skin and human health will not
be affected” as well as the claims that “we know skin and human health
will be affected” are premature assumptions that lack sufficient
scientific basis."
Given that this highly-qualified, world-renowned expert has conducted a
review of the millimetre wave research on health effects and come to this
conclusion, I contend that the Ministry of Health should apply the
'Precautionary Approach', discontinue support for the roll-out of 5G and
withdraw statements
giving premature assurances of safety.
My second question, therefore, is as follows:  On what basis can the
Ministry of Health support the roll-out of 5G and give the New Zealand
public assurances of safety, given that expert opinion is clearly stating
that insufficient research has been done to make any conclusions about
either adverse health effects or safety?

Yours faithfully,

Michael Vaughan

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