Prof. Girish Kumar's comments on "DOT Report for Allahabad HC" on EMF Radiation and Health

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Government of India

Ministry of Communications & Information Technology

Department of Telecommunications

Report of the Committee

Constituted as per direction of Hon’ble High Court Allahabad,

Lucknow Bench in its order dated 10.01.2012

in

writ petition No. 11275 (M/B) of 2010

ON

ISSUES RELATED

TO

EMF RADIATION

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Report

1. Introduction :

Hon’ble High Court Allahabad, Lucknow Bench in order dated 10.01.2012 in writ

petition No. 11275 (M/B) of 2010 in the matter of Shri Ram Singh Jauhari Vs UOI

& Others issued following direction:

“ We direct the Government of India to constitute a Committee of five members of

Electrical Engineering Department of the IITs of Mumbai, Kharagpur, Kanpur,

Delhi, Roorkee including Prof. (Dr) Girish Kumar and four other prominent

persons of other scientific institutions of the country like AIIMS (Delhi), Indian

Council of Medical Research etc to submit a report so that the Government of

India may take necessary precaution while granting permission for establishment

of mobile towers as well as to regulate sales of mobile with necessary

precautions.”

In compliance of above court order, a committee was constituted vide DoT letter

No. 17-63/2011-CS-III Dated: 20.08.2013. Nominations were asked from the

heads of the respective organizations. Based on the nominations received from

IIT Mumbai, IIT Delhi, IIT Kharagpur, IIT Kanpur, IIT Roorkee, AIIMS Delhi,

Indian Council of Medical Research New Delhi, Indian Institute of Toxicology

Research Lucknow, Science & Engineering Research Board (SERB) under the

Department of Science & Technology (DST), members have been included in the

Committee. Further, Department of Telecom has nominated four officers working

in the field of EMF Radiation. Following is the constitution of the committee,

consisting of thirteen members:

1. Shri S. S. Sirohi, Senior Deputy Director General (Telecom Enforcement,

Resource & Monitoring – Term) (TERM) DoT – Chairman

2. Dr. (Prof.) Ajoy Chakraborty, Professor, Department of Electronics & Electrical

Communication Engg, IIT Kharagpur, --Member

3. Dr. (Prof.) Ajit Kumar Chaturvedi, Dean of Research & Development, IIT

Kanpur, -- Member

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4. Dr. (Prof.) Ranjan Mallik, Department of Electrical Engineering, IIT Delhi, --

Member

5. Dr. (Prof.) S.N. Sinha, Emeritus Fellow, Deptt. of Electronics & Communication

Engg., IIT Roorkee--Member

6. Dr. (Prof.) Girish Kumar, Member of Electrical Engineering Department of the

IIT Mumbai --Member

7. Dr. R. S. Sharma, Deputy Director General (SG) Division of RCH, Indian

Council of Medical Research (ICMR) --Member

8. Dr. Sarat P. Chandra * AIIMS, New Delhi- Member, (Dr. P. P. Kotwal, AIIMS

attended the first meeting on 25-09-2013)

9. Dr. R.C. Murthy, Chief Scientist and Head, Analytical Chemistry from Indian

Institute of Toxicology Research Lucknow--Member

10. Shri S. S. Kohli, Director / Sc. 'F', SERC Division from Science & Engineering

Research Board (SERB) under the Department of Science & Technology (DST)

--Member

11. Shri U. K. Srivastava, Deputy Director General, Telecom Engineering Center

(TEC), New Delhi, DoT--Member

12. Shri Nitin Jain, Deputy Director General (CS), New Delhi, DoT--Member

13. Director (CS-III), DOT-- Member Convenor

/Shri Rama Shankar Ram Director (CS-TP), DoT– Alternate member convenor

* Dr Vivek Tandon from AIIMS attended the meetings as alternate member in

place of Dr. Sarat P Chandra.

2. Proceedings of the Committee

2. A. 1st meeting of this Committee was held on 25/9/2013 wherein deliberations were

held in accordance with the above said court order and it was decided to study

the following documents, which is in line with the directions of Hon’ble High

Court.

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1) Members of the Committee shall study the Report of Prof. (Dr.) Girish

Kumar submitted by petitioner as per Hon’ble High Court order dated

10.01.2012

2) Members shall also give their views/ comments on the EMF radiation

exposure norms revised by DoT vide license amendment dated

30/12/2011, which are based on the acceptance of recommendations of

inter-ministerial committee through office memorandum dated 17/11/2011

on Electro-magnetic Field (EMF) radiation. These revised EMF radiation

exposure norms issued on 30/12/2011 came into effect from 01/09/2012.

Above documents were made available to all the members of the Committee. Dr.

R.C. Murthy from IITR, Lucknow and Prof. (Dr.) Girish Kumar, IIT Mumbai did not

attend the first meeting. Prof. (Dr.) Girish Kumar, IIT Mumbai circulated an email

to this effect to all the members making certain observations on the constitution

of the committee, which were discussed in this meeting. Minutes of meeting are

attached in Annexure-I.

The committee noted the current status of various guidelines adopted in India

with regard to EMF radiation which are as follows:

(i) EMF radiation norms for mobile base stations (Cell towers):

India adopted the EMF radiation limits recommended by International

Commission on Non – Ionizing Radiation Protection (ICNIRP) through the

amendment of licenses of the telecom service providers on 04-11-2008.

Further, in view of the Office Memorandum dated 17-11-2011, Department of

Telecom, vide amendment in the License agreement of the Telecom Service

Providers dated 30-12-2011, has adopted stricter norms, following a

precautionary approach on EMF exposure limit for the radio frequency

Electro-magnetic Field (EMF) by mobile base stations i.e. Base Transceiver

Stations (BTSs) which are 1/10th of the limits prescribed by International

Commission on Non – Ionizing Radiation Protection (ICNIRP).

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The revised norms became effective from 01-09-2012.

(ii) EMF radiation norms for Mobile Handset - Specific Absorption Rate

(SAR):

In view of the Office Memorandum dated 17-11-2011, Department of

Telecom, has adopted stricter norms for SAR levels of mobile handsets.

The new revised SAR limit of 1.6 Watt/Kg, averaged over a mass of 1 gram of

human tissue, has replaced the earlier existing limit of 2 Watt/Kg averaged

over a mass of 10 gram of human tissue, which was in place since 01-09-

2008.

These revised SAR norms for new mobile handsets have become effective

from 01-09-2013.

2. B. Discussion on the issues raised in the Petition before the Hon’ble High

Court:

Subsequent meetings of the committee were held on 21/10/2013, 08/11/2013,

28/11/2013, 16/12/2013 and 30/12/2013.

The Committee noted, inter-alia, the following observations of the Hon’ble High

Court in its order dated 10-01-2012:

“………….

On the other hand, the report of Prof. Girish Kumar filed with the

supplementary affidavit seems to raise important questions with regard to

safety measures adopted by the Government of India which is precisely

narrated as under:

1. The current exposure safety standards are mainly based on the

thermal effects, which are inadequate. Non-thermal effects are several

times more harmful than thermal effects. According to Dr. Girish

Kumar, Microwave radiation is classified as thermal and non-thermal.

Out of two, non-thermal effects are more harmful.

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2. With regard to Microwave Heating Concept, 4.2 KW of microwave

power raises temperature of 1 Litre of water by 1 degree C in 1

second. In a microwave oven, temperature of one cup of water

increases from 30 degree to 100 degree C in approx. 70 seconds.

With 1W power temperature will increase by 1 degree C in 500

seconds. Temperature of ear lobes increases by approx. 1 degree C

when cell phone is used for approx. 20 minutes.

3. According to Dr. Girish Kumar, different safety measures have been

provided with regard to cell phone as well as SAR in different States of

U.S.A. For example, San Francisco Government has made it

mandatory for the industry to display SAR value for each set.

According to him, people living within 50 to 300 meter radius of the

tower are in the high radiation zone and are more prone to ill-effects of

electromagnetic radiation. Four cancer cases in three consecutive

floors (6th, 7th and 8th) directly facing and at similar height as the

mobile phone towers of four telecom companies placed on the roof of

opposite building has been found to be true experiment in Worli,

Mumbai. With regard to power density, it has been found that it

increases for multiple carriers and multiple operators on the same roof

top or tower. Dr. Girish Kumar found that the persons residing in

vicinity of Cell Tower are prone to suffer with cancer.

Overall reading of the report of Dr. Girish Kumar prima facie reveals

that the people residing in the vicinity of Cell towers may suffer from

different diseases which includes boils, drying up the fluids around

eyes, brain, joints, heart, abdomen, etc along with change of electrical

activity of brain. Use of mobile phone before bed also disturb the

sound sleep.

Courts are not experts. Prima facie, the report of Dr. Girish Kumar

reveals that the establishment of mobile tower in residential areas of

the cities may be harmful. Different anamolies, drawback and

Formatted: Font color: Red

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problems considered by Dr. Girish Kumar in his report, prima facie, do

not seem to have been taken into account by the Government of India.

…………………….”

In consideration of the observations and directions of Hon’ble High court,

members of the committee took note of the fact that the petitioner has relied on

the report of Prof. (Dr.) Girish Kumar. As Prof. (Dr.) Girish Kumar is also a

member of this Committee, he was requested to make a presentation and

express his views on the subject matter considering the matter in the petition and

observations & directions of Hon’ble High Court. Prof. (Dr.) Girish Kumar made a

presentation to the Committee on his views on the issues raised in the said

petition. Keeping in view the directions of the Hon’ble High Court, detailed

discussions took place on these issues. Prof (Dr.) Girish Kumar’s presentation

included all the issues that the petitioner had submitted before Hon’ble High

Court. The gist of discussion is as placed below in the Table-1:

Table-1

Sl

.

Main issues brought out in the petition

– presented by

Prof. (Dr.) Girish Kumar

Details of deliberations held by the

Committee

1 People living within 50-300 meter radius

are more prone to dangerous ill effects of

EMR on human health. There are some

evidence to this effect.

It was explained to the Committee

members by him that if present ICNIRP

guidelines are followed then human body

would absorb microwave energy of 583.2

kw-sec which would amount to keeping

human body in microwave oven for 19

minutes/day.

Thermal effects of EMF radiations are

explained in this example as there is

a comparison with microwave

heating. It has been assumed by Prof.

(Dr.) Girish Kumar that human body is

a cylinder of fluid and has no thermal

regulation of its own. Further, to

understand the effect of EMF

radiation of human body, following

factors need to be considered:

a) According the scientific data

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Further, with regard to Microwave

Heating Concept, 4.2 KW of microwave

power raises temperature of 1 Litre of

water by 1 degree C in 1 second. In a

microwave oven, temperature of one cup

of water increases from 30 degree to 100

degree C in approx. 70 seconds with 500

watt of microwave power. With 1W power

temperature will increase by 1 degree C

in 500 seconds.

The temperature rise can be calculated

using microwave heating equation, which

is the basis of microwave heating.

Increase in the temperature is linearly

proportional to the power and time.

Temperature of ear lobes increases by

approx. 1 degree C when cell phone is

used for approx. 20 minutes

published in reputed scientific

journals, the Absorption cross-

section (ACS), which is defined

as the ratio of power absorbed

to incident power density, of

human body to EMF radiation

is between 0.2 to 0.3 within

mobile frequency bands as it is

frequency dependent. In the

same paper, values mentioned

are 0.4 to 0.5 at 1GHz but the

members chose to write lower

value, which is around 2 to 3

GHz.

These values have been

determined by considering that

the human body is totally

immersed in a uniform EMF.

Such a situation can only be

created in an isolated

environment like laboratory.

For an actual directional

exposure, the value of ACS will

be even less.

After this issue was raised in

the committee, I did the

measurement in the antenna

lab at IIT Bombay, the

reflected wave was less than

5%. This fact was presented to

the committee but they chose

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to ignore for the reason best

known to them.

b) Human body is not

homogeneous. It consists of

several layers like skin, tissue,

fat, muscle etc and different

layers of body have different

dielectric constants.

c) Only about 20%-30% of the

human body shall be actually

exposed to the directional

beam of EMF radiation from

the BTS antenna. In his

computations, Prof (Dr.) Girish

Kumar has assumed that the

full EMF radiated power (at

peak traffic value) is falling on

the human body from all sides

i.e. from every angle in 360o

and also from top and bottom

as if live human being is kept

in a reverberation chamber

having EMF radiation from all

sides at peak values. He

further assumes that the entire

electro-magnetic (E.M.) power

in the incident wave enters into

the human body which is not

correct. the reflected wave is

less than 5%.

d) BTS generally radiates at

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much lower power than peak

power. (there are many

transmitting tower antennas on

the same roof top, so total

power transmitted from

multiple antennas can be

greater than peak power of a

single transmitting antenna).

e) World Health Organisation

(WHO) in its fact sheet No. 193

of 2011 has mentioned that at

the frequencies used by mobile

phones, most of the energy is

absorbed by the skin and other

superficial tissues, this is not

correct, there is depth of

penetration of several

centimeters at 900 and 1800

MHz resulting in negligible

temperature rise in the brain or

any other organ of the body.

WHO fact sheet No. 193 of

2011 also mentions about cell

phone as possibly carcinogen

(Class 2B)

Prof. (Dr.) Girish Kumar has agreed

that all these factors have not been

considered in the calculations given

by him. I did not agree with the

committee but they chose to write for

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the reason best known to

them.Further, Prof. Girish Kumar has

also not taken into account a very

important factor i.e. the self thermo-

regulatory mechanism of the human

body.

As far as thermal effects are concerned, committee also noted that power density of the Sun’s radiation is of the order of about 1000 Watt/m2

which is more than 1000 times higher than EMF radiation power from BTSs. However, due to the thermo-regulatory mechanism of human body, temperature of human body remains regulated even if exposed to very high thermal radiation from Sun. Sun exposure is not continuous whereas microwave radiation is 24x7 due to cell tower radiation. Sun heating is from outside to inside. The skin of human body acts as an insulator from sun and as the temperature increases, skin will either feel the burning sensation or it starts sweating. also, clothes act as an insulator. In addition, air breeze takes away the heat. Also, people who take sun bathing, have reported skin cancer. Whereas, microwave heating is from inside to outside. It penetrates the skin and heats up the blood, fluid, fat, etc. This heat is trapped inside the human body with no escape through the skin.

Hence, the committee observed that

the conclusion in Prof. (Dr.) Girish

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Kumar’s report that ICNIRP guidelines

would result into absorption of

microwave energy of 583.2 kw-sec in

human body and would amount to

keeping human body in microwave

oven for 19 minutes/day is incorrect,

highly misplaced and misleading.

(ICNIRP guideline is only for short

term exposure and not for 24x7. Also,

there are multiple transmitting

antennas. In addition, for GSM1800,

ICNIRP mentions safe level of 9.2

Watts/square meter, which is worse).

Further, at distances in the range of

50-300 meters, the power density of

the signal from BTS becomes very

low as compared to the prescribed

precautionary maximum limits of EMF

radiation in India. Only a fraction of

power radiated from BTS reaches a

particular spot in the EMF lobe of

power radiation pattern, where a

human being may be present.

Further, considerable attenuation of

the E.M. wave occurs as it passes

through the concrete walls and roof of

the buildings. Committee also noted

that radiation levels below and near to

antenna are very low due to height

and tilt of the antenna considering the

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antenna radiation pattern. Actual

measured EMF radiation at any place

vis-à-vis the radiation limit as

recommended by DoT is the criteria to

take the precautionary measures. We

have been repeatedly telling that

India's precautionary limit of 450

miilwatts/square meter for GSM900 is

very high for 24x7 exposure, it should

be less than 0.1 miilwatts/square

meter for 24x7 exposure.

In view of above discussion, the

committee notes that irrespective of

the distance, so long as the EMF

radiation power levels, in the vicinity

of Base Stations, are below the

prescribed limits, limit must be

reduced to less than 1 miilwatts/m2

there cannot be any cause of adverse

thermal what about non-thermal

effect? health effects on human

beings due to base station radiation.

So far as non-thermal effects of EM

radiation are concerned, a lot of

research is going around the world

but currently there is no

CONCLUSIVE scientific evidence

which establishes that EMF has

harmful non-thermal effects. BIO-

INITIATIVE report 2012 has given

Formatted: Superscript

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references of 3800 scientific research

papers but committee chose to ignore

all the time due to reasons best

known to them However, some

countries are taking a precautionary

approach by reducing EMF levels

below those specified by ICNIRP and

India is one of them which has

reduced the prescribed EMF radiation

levels by a factor of 10. (many

countries have chosen 1/100 to

1/1000th level of ICNIRP. They care

for the health of their citizen. We have

to also take care of health of people in

India).

Thus, the committee concludes

that the assertion by Prof. (Dr.)

Girish Kumar that people living

within 50-300 meter radius of

mobile tower are more prone to

dangerous ill effects of EMF

radiation, are not backed by

conclusive scientific evidences. (I

also mentioned to the committee

that people living in the range of 10

to 50 meter are even more prone to

health hazards as many towers are

installed within this There are

many epidemiological studies,

which have reported health

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hazards to the people living within

300m, such as, sleep disorder,

headaches, irritation,

cardiovascular problems, cancer,

etc. but committee chose to ignore

it.)

Regarding Radiation from Mobile

Hand Set:

As far as rise of temperature of ear

lobes by approx. 1 degree Celsius is

concerned on using cell phone for

approx. 20 minutes, Committee is of

the view that heat energy is

generated due to the working of

electronic components in the mobile

phone as well as EMF radiation from

mobile phone falling on the ear lobe.

Committee further noted the fact that

the thermo-regulatory mechanism of

human body takes care of the

localized heating, thus the

temperature rise of ear lobe is limited

to less than 1˚C by use of mobile

handsets very close to the ear lobe

even for continuous use for longer

durations also. The claimed biological

effects of EMF radiations are

discussed in detail in item No. 4 of

this table (TABLE-1).

Committee referred to the paper,

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"Calculation of change in brain

temperatures due to exposure

to a mobile phone" by G M J Van

Leeuwen et al, published in 1999. They presented

only theoretical results whereas measured results

show much higher temperature rise. Committee

chose to selectively write lower value.

However, so far, no conclusive

evidence on adverse health effects

by EMF radiation from mobile

handset has been found

internationally by World Health

Organization (WHO). As per the

available evidences, such changes

are described as reversible and

further studies are underway in

different forums to establish any

linkage, if any, of adverse health

effects with EMF radiation from

mobile handsets. (No conclusive

evidence does not mean no evidence.

WHO accepted cell phone as possibly

Carcinogen in 2011, where as earlier

they had not classified as Class 2B.

The reason is that radiation hazards

are cumulative in nature and as

usage is increasing with time, larger

number of people are reporting health

hazards.

Conclusion:

In view of the discussion as above,

committee concludes that these

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findings of Prof. (Dr.) Girish Kumar

of comparing heating of water in

microwave oven with human health

effects of EMF radiation from

mobile tower are incorrect. (people

do cook non-veg food in the

microwave oven, which is based

on heating principle of water

molecules present in the food

items)

Self thermo regulation of human

body is an important aspect which

has been totally ignored in this

example. (Self thermo regulation is

effective for short duration but if

the source is continuous, then it

fails. Human body has fighting

mechanism, which is not effective

forever especially for children,

pregnant women, older people,

patients, etc.)

Further, as regard the

temperature rise of ear lobe and

dangerous ill effects caused by it

due to radiation from mobile

phones/handset are not

conclusively supported by proven

scientific studies.

Committee referred to the paper,

"Calculation of change in brain

temperatures due to exposure

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to a mobile phone" by G M J Van

Leeuwen et al, published in 1999. They presented

only theoretical results whereas measured results

show much higher temperature rise. Committee

chose to selectively write lower value.

Therefore such comparisons are

highly misleading and may create

unfounded fear and panic in the

minds of people, which is totally

unwarranted and should be

avoided. Creating awareness to the

people is extremely important. Cell

operators and their associates are

giving false assurance to the

people that there are no health

hazards. Why are they ignoring

1000's of scientific papers showing

adverse effects.

2 If one stands 1 meter away from cell

tower antenna, body temperature would

rise to 2˚F in 1 hour and by 8˚F in 4

hours.

Increase in the temperature is linearly

proportional to the power and time. The

equation is given in Point 1.

Self thermo regulation is effective for

short duration but if the source is

continuous, then it fails. Human body

has fighting mechanism, which is not

effective forever especially for

children, pregnant women, older

This assertion of Prof. (Dr.) Girish

Kumar is related to thermal effects of

EMF radiation on human body.

In continuation of deliberations of the

committee on earlier item regarding

thermal effects, committee notes the

following:

The assumptions used by Prof. (Dr.)

Girish Kumar are hypothetical. Such

assumption of a person being close to

and in front of very narrow beam of

antenna at that height in the air is

rhetorical and impractical.This

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people, patients, etc. example was given to prove cell

operators and their associates that

non-ionizing radiation can cause

damage. Further, there is no scientific

evidence available so far to prove that

the temperature of the human body

steadily rises by 2˚F in one hour and

8˚F in 4 hours and so on inspite of

self thermo regulation. This

calculation is based on microwave

heating equation, which is the basis

of microwave heating. Also, self

thermo regulation is effective for

short duration but if the source is

continuous, then it fails. Human

body has fighting mechanism,

which is not effective forever.

The rise in body temperature due to

EMF exposure depends upon whole-

body SAR for which the FCC limit for

general public is 0.08 W/Kg. There

are ample number of published

scientific studies which show that at

these SAR levels, the rise in body

temperature is of the order of 0.1

degree centigrade (0.18˚F) for long

exposure times. (For cell tower

radiation, limit is generally defined in

watts/m2.) Formatted: Superscript

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The thermal time constant and

thermo-regulatory mechanism of

human body have been totally

ignored by Prof. (Dr.) Girish Kumar.

self thermo regulation is effective

for short duration but if the source

is continuous, then it fails. Human

body has fighting mechanism,

which is not effective forever

especially for children, pregnant

women, older people, patients,

etc.Thus, the calculation given by him

has no scientific basis as far as

human body or living organisms are

concerned in real situations. The

factors affecting the EMF exposure to

human body as deliberated in point 1

above also apply in this case.

The sole criteria of safety is that with

present level of power radiated from

antenna, the radiation level at the

location around the tower where the

people could be present should be

within the limits as prescribed by the

DOT which are already 1/10th of

ICNIRP norms. DOT limit of 1/10th of

ICNIRP norms is very high for 24x7

exposure, it should be less than 0.1

milliwatts/m2

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Conclusion:

The committee has come to the

conclusion that Prof. (Dr.) Girish

Kumar has made an over

simplification of the complex

phenomenon of human response

to such stimuli.

Such unfounded and hypothetical

analysis is ill conceived. This is

complete misrepresentation of

actual position and shall create

only confusion, misperception and

unfounded fear in the minds of

general public, which should be

avoided. (Creating awareness to

the people about possible health

hazards is important. Human body

is complex that is why some

simplifications have been made to

explain to general public. Cell

operators and their associates take

advantage of this complex problem

to mislead people that health

hazards are not conclusively

proven (not conclusive does not

mean no proof)

3 Prof. (Dr.) Girish Kumar while quoting a

newsletter published by him (Sept-Oct,

2013) has referred to Federal

Communications Commission (FCC)

Committee makes the following

observations:

a. FCC limits for occupational

exposure to EMF radiation for

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guidelines of USA. According to his

interpretation about the FCC guidelines,

power density limits from cell tower

should beis f/300 mw/cm2 for 6 minutes

use and f/1500 mw/cm2 for 30 minutes

use.

As per his interpretation, for 24 hour

exposure (which is the case, as the cell

tower radiates continuously) FCC

guidelines recommend exposure limit of

12.5 mw/m2.

With regard to mobile handset, India has

adopted SAR value 1.6 w/kg averaged

over 1 gm of tissue which is same as

FCC guidelines.

Prof. (Dr.) Girish Kumar argued and

interpreted that use of mobile phone only

upto 6 minutes is recommended by FCC

but he has found use of phone safe upto

10 to 30 minutes. I had also mentioned

that there is a safety margin of 3 to 4 in

the guideline. Also, 10 to 30 minutes is

safe depending upon SAR value of

phone

300-1500 MHz frequency are

f/300 mwatt/cm2 with average

measurement exposure time

of 6 minutes. Whereas for

general population, EMF

radiation exposure for 300-

1500 MHz frequency, the FCC

limits are f/1500 mwatt/cm2

with average measurement

exposure time of 30 minutes.

These two limits are for

different environments and

hence can not be compared.

b. While the FCC standard for

radiation is f/1500 mwatt/cm2,

when expressed in the unit of

watts/m2, this limit becomes

f/150 watts/m2. This is far

relaxed than the limit of

ICNIRP which is f/200 watt/m2.

The FCC limits are followed in

USA, Canada, and Japan

besides few more countries.

India has adopted 1/10th of

ICNIRP norms which is more

stringent and is f/2000 watt/m2.

c. While, measuring this

parameterit is not written

anywhere measuring,

everywhere it is written

exposure, the average of 30

minutes of radiation is taken so

as to avoid any misreading due

to instantaneous increase. The

contention of Prof Girish

Kumar that the same limit,

when averaged over 6

minutes, becomes f/300

mw/cm2 is total

Formatted: Font color: Red

Page 23 of 70

misunderstanding of the

standard.

d. Cell towers are designed to

radiate continuously for

providing reliable and

continuous mobile phone

service. Committee observed

that this interpretation of Prof.

(Dr.) Girish Kumar, of reducing

the radiated EMF power from

cell tower depending on period

of use, is baseless and

hypothetical.

e. Committee members explained

that duration of thirty minutes

mentioned in FCC guidelines is

the duration of any sample

over which the measurement

exposure should be done and

average of the values gathered

during these thirty minutes

should be taken as the value of

EMF radiation power density

observed. Committee noted

that the FCC guidelines are

available in public domain with

the above explanation. These

guidelines (FCC No. OET 56)

have also been shared among

all the members of the

Committee. (ANNEXURE-II)

Further, averaging is used in

any measurement to avoid

judgement on any

instantaneous observation.

This is a very well

internationally established

scientific procedure of

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measurement.

f. Committee further noted that in

case of ICNIRP guideline,

power density is to be

averaged over any 6 minutes

period for the purpose of

measurement no where it is

written measurement,


exposure of EMF radiation.

ICNIRP guidelines mentions

that “For frequencies between

100 KHz & 10 GHz, Seq (i,e,

power density) are to be

averaged over any 6 minute

period.” This no where it is

written measurement,


exposuremeasurement

standard however does not

mean that the radiation

exposure to the public has to

be limited to only six minute,

as being made out in the

meeting by Prof (Dr.) Girish

Kumar.

g. It was opined by the committee

that as long as the absolute

prescribed limit of EMF

radiation power level is not

exceeded, duration of

exposure is not significant

taking into account the self

thermal regulatory mechanism

of the human body. Rather,

absolute prescribed limit of

EMF radiation power level are

recommended by the

international bodies keeping in

Page 25 of 70

view the continuous radiation

from cell towers. Duration of

exposure is extremely

important. If food is cooked in

the microwave oven (even at a

lowest power level) for 10

minutes or 100 minutes, there

will be huge effect. Self

thermo regulation is

effective for short duration

but if the source is

continuous, then it fails.

h. The limit of 6 minutes radiation

at the recommended power

levels of EMF radiation by FCC

as deduced by Prof. Girish

Kumar is absolutely incorrect

and gross misrepresentation of

the FCC recommendation.

Similarly, the limits deduced by

him for 24 hours use is also

utter misrepresentation of the

FCC standard. (FCC has

clearly mentioned reduced

guidelines for 30 minutes

compared to 6 minutes. I had

clearly mentioned to the

committee that 24 hours is an

extrapolation but they chose to

ignore.

i. In the context of 30 minutes

average exposure, FCC in

their document No. OET

Bulletin 56 has clarified that

“For such public exposure

situations, the MPE (Maximum

Permissible Exposure) limits

normally apply for continuous

exposure. In other words, as

Page 26 of 70

long as the absolute limits are

not exceeded, indefinite

exposure is allowed.” Duration

of exposure is extremely

important. If food is cooked in

the microwave oven (even at a

lowest power level) for 10

minutes or 100 minutes, there

will be huge difference. Same

is true for a person standing in

the sun for 10 or 100 minutes.

j. Same applies to the

measurement of SAR values

for average 6 minutes and has

no relation to the duration of

use of mobile phone by the

people. Interphone study has

clearly mentioned that people

who use cell phone for longer

duration (30 minutes or more)

are more prone to health

hazards than who use for less

than 6 minutes.

Conclusion:

Committee after carefully

deliberating all the aspects

concludes that the interpretations

and projections given by Prof (Dr.)

Girish Kumar are absolutely

incorrect and are complete

misrepresentation of the facts. It is

other way around, committee

chose to mis-represent the

interpretations and projections

given by me for the reasons best

Page 27 of 70

known to them.

4 Prof. Girish Kumar explained that the

EMF radiation causes biological effects

such as cancer, brain tumor, localized

heating, drying up of fluids around eyes,

brain, joints, heart, abdomen etc, sleep

disruption headache, Fatigue, Dizziness

etc. He also explained the effect of EMF

radiation on environment particularly on

Birds and bees also.

The non-thermal effects due to EMF

radiation on human body are also

termed as Biological effects.

Committee noted that the

international studies have taken into

account the non-thermal (biological)

effects of EMF radiation on human

body. The international standards

have also taken in to account the

biological effects before prescribing

the standards.

1. WHO in its Facts sheet no. 304

of May 2006 has stated that

“International exposure

guidelines have been

developed to provide

protection against established

effects from RF fields by

International Commission on

Non-Ionizing Radiation

Protection (ICNIRP,1998) and

the Institute of Electrical and

Electronics

Engineers(IEEE,2005).

National authorities should

adopt international standards

to protect their citizens against

adverse levels of RF fields.

Page 28 of 70

They should restrict access to

areas where exposure limits

may be exceeded.” All the

above are outdated. In 2011,

WHO reported cell phone as

possibly carcinogen (Class

2B). What is the point in

mentioning earlier reports?

Also, there are growing

evidences of health hazards in

the last few years (as cell

phone/tower radiation is

cumulative in nature). There

are 1000's of scientific papers

reporting health hazards but

committee chose to ignore.

2. After going through the ICNIRP

report, committee finds that biological

studies related to EMF exposure have

been extensively covered in the

report of ICNIRP on page no 505

under the heading “Biological Basis

for Limiting Exposure (100khz-

300Ghz)”. It is noted by the

committee that ICNIRP report, inter-

alia, takes into account (i)

Epidemiological studies (ii)

Reproductive outcome (iii) Cancer

studies (iv) laboratory studies (v)

Volunteer studies ( vi) Cellular and

Page 29 of 70

animal studies (vii) Special conditions

for pulsed and amplitude modulated

waveform. Both direct and indirect

effects of EMF have also been taken

into account for conducting biological

studies.

3. Committee noted that all these

facts are already documented in the

ICNIRP report. After consideration of

the study of biological effects of EMF

radiation only, ICNIRP has come out

with detailed guidelines for

recommending the EMF exposure

limits. (ICNIRP is an NGO, whose funding

has been questioned by large number of people.

Google search words as "ICNIRP funding" leads to

several websites:

The following websites mentions about

Weaknesses in ICNIRP’s rationale for its 1998

guidelines and Uncertainties over ICNIRP’s

membership and aims:

http://wiredchild.org/component/content/article/46

-hidden/99-icnirp.html

The following paragraph is taken from the above

site:

"It should be noted that ICNIRP is not a

transparent organization. It has never disclosed

the sources of its funding nor the procedures for

the selection of its members. ICNIRP was

established by Mike Repacholi, who has long had

financial ties to both the telecom and electric

utility industries. “

The above has been reported in my

newsletter, which was presented to

committee.

Further, according to online reply to a

Page 30 of 70

question by WHO dated 20th Sept

2013, WHO has recognised that “to

date studies provide no indication that

environment exposure to RF fields,

such as from base station, increase

the risk of cancer or any other

disease.” Moreover with regards to

other Health Effects this release

mentions that:

“Scientists have reported other health

effect of using mobile phones

including changes in brain activities,

reaction times, and sleep patterns.

These effects are minor and have no

apparent health significance. More

studies are underway to try to confirm

these findings.”

Only second part of the WHO reply is

included. First part mentions that

exposure to the radiofrequency (RF)

fields emitted by mobile phones is

generally more than a 1000 times

higher than from base stations and

there is greater likelihood of any

adverse effect being due to handsets.

THIS IS VERY IMPORTANT, it

implies that base station radiation is

1/1000 of mobile phones. We have

measured radiation density of many

mobile phones, when they are in the

Page 31 of 70

talk mode, and it is around 100

mW/m2, so 1/1000th will be

0.1mW/m2. Thus, the safe radiation

norm should be around 0.1mW/m2

and not 450mW/m2.

Other international studies have also

studied biological effects due to EMF

radiation and found that Biological

effects corresponding to generally

reversible changes in the inner

functioning of the body are observed,

as is also found in the case of

exposure to different stimuli of

everyday life. However, there are no

conclusive evidence (no conclusive

evidence does not mean no

evidence) to establish any causal link

between the effect of EMF radiation

with biological effects described in

cell models, animals or humans, and

any possible resulting health effects.

It is highly relevant to mention that the

Committee took note that while

summarizing the Health effect of EMF

radiation, WHO has mentioned the

following:

“…..Heating is the main biological effect of the electromagnetic fields of radiofrequency fields. In microwave ovens this fact is employed to warm up food. The levels of radiofrequency



Page 32 of 70

fields to which people are normally exposed are very much lower than those needed to produce significant heating. The heating effect of radio waves forms the underlying basis for current guidelines. Scientists are also investigating the possibility that effects below the threshold level for body heating occur as a result of long-term exposure. To date, no adverse health effects from low level, long-term exposure to radiofrequency or power frequency fields have been confirmed, but scientists are actively continuing to research this area. Biological effects or health effects? What is a health hazard? Biological effects are measurable responses to a stimulus or to a change in the environment. These changes are not necessarily harmful to your health. For example, listening to music, reading a book, eating an apple or playing tennis will produce a range of biological effects. Nevertheless, none of these activities is expected to cause health effects. The body has sophisticated mechanisms to adjust to the many and varied influences we encounter in our environment. Ongoing change forms a normal part of our lives. But, of course, the body does not possess adequate compensation mechanisms for all biological effects. Changes that are irreversible and stress the system for long periods of time may constitute a health hazard. An adverse health effect causes detectable impairment of the health of the exposed individual or of his or her offspring; a biological effect, on the other hand, may or may not result in an adverse health effect.

Page 33 of 70

It is not disputed that electromagnetic fields above certain levels can trigger biological effects. Experiments with healthy volunteers indicate that short-term exposure at the levels present in the environment or in the home do not cause any apparent detrimental effects. Exposures to higher levels that might be harmful are restricted by national and international guidelines. The current debate is centred on whether long-term low level exposure can evoke biological responses and influence people's well-being. …………………. Conclusions from scientific research In the area of biological effects and medical applications of non-ionizing radiation approximately 25,000 articles have been published over the past 30 years. Despite the feeling of some people that more research needs to be done, scientific knowledge in this area is now more extensive than for most chemicals. Based on a recent in-depth review of the scientific literature, the WHO concluded that current evidence does not confirm the existence of any health consequences from exposure to low level electromagnetic fields. However, some gaps in knowledge about biological effects exist and need further research. ………………..” (Source: WHO website: http://www.who.int/peh-emf/about/WhatisEMF/en/index1.html Copy attached as Annexure-III) (This is an Extract from Electromagnetic

Page 34 of 70

fields published by the WHO Regional Office

for Europe in 1999. This report is an

outdated report and should be discarded

after WHO reported cell phone as possibly

carcinogen (Class 2B) in 2011. I do not know

why committee members chose to report

outdated report. They should be concerned

about health of the public. Committee has noted that the claims

made by Prof. (Dr.) Girish Kumar on

health effects of EMF radiation are

not supported by any scientific

evidence Prof. (Dr.) Girish Kumar

appears to have heavily relied only on

Bio-Initiative Report 2007 & 2012.

This report is one of the extreme view

among thousands of studies on the

subject and does not provide any

conclusive evidence.

Committee noted that WHO, after

studying approximately 25,000

studies over past 30 years has

concluded that current evidence does

not confirm the existence of any

health consequences from exposure

to EMF radiation.

WHO has concluded that considering

the very low exposure levels and

research, there is no convincing

scientific evidence that the prescribed

EMF exposure from base station

Page 35 of 70

cause adverse health effects.

As regards the health effect of

radiation from prolonged use of

mobile phone, International Agency

for Research on Cancer (IARC), an

agency of WHO, has classified

radiofrequency electromagnetic fields

as possibly carcinogenic to humans

(Group 2B), a category used when a

causal association is considered

credible but when chance, bias or

confounding cannot be ruled out with

reasonable confidence.

WHO has further stated that a large

number of studies have been

performed over the last two decades

to assess whether mobile phones

pose a potential health risk. To date,

no adverse health effects have been

established as being caused by

mobile phone use.

Committee also noted that in fact

substances, mixtures and exposure

circumstances classified by the

International Agency for Research on

Cancer (IARC) as ‘Group 2B’, inter-

alia, include coffee, Aloe vera (whole

leaf extract), Pickled vegetables

(traditional in Asia), Talc-based body

Page 36 of 70

powder etc. (source IARC

Monographs)

However, more studies are underway

at various forums (National as well as

International) to find any conclusive

evidence to the harmful health effect

from EMF radiation from cell towers

and mobile phones.

Conclusion:

The Committee is of the opinion

that the limits adopted by India for

EMF radiation from cell tower as

well as from mobile phones

account for all the biological

effects of radiation, as these limits

are much lower than internationally

adopted ICNIRP recommendations

which take in to consideration

thermal as well non-thermal effects

of radiation.iCNIRP does not

account for non-thermal effects

More studies are underway

particularly relating to prolonged

use of Mobile phones. Hence at

this stage, there is no cause of

alarm with regard to the possible

dangerous ill effects on human

health as mentioned by Prof. (Dr.)

Page 37 of 70

Girish Kumar.

However, national authorities must

keep a watch on the studies and

research work being carried out in

this area for finding conclusive

evidence, if any.

5 The author presented a case study of

Usha Kiran Building, Worli, Mumbai

wherein six cases of cancer were

reported. This building was facing the

Antennas placed by four telecom

companies on the opposite side of

another building.

Further, while giving example of various

countries, he has brought out during

discussions that in Mumbai at Riddi Park,

Thakurlee, within 4 months of occupying

the top floor flat, Mrs. Bhat was

diagnosed with brain tumour and her

neighbour delivered a baby with cancer

of spinal cord i.e. within a duration of 9

months of pregnancy. This has also been

brought out by him in his report submitted

to Secretary, DOT in December 2010.

(this part has been reported in Mobile

Tower Grievance Forum,

http://mtgf.blogspot.in/

The Committee’s response against

point 4 above details the biological

studies which have not been taken

into consideration by ICNIRP while

recommending the exposure limits of

EMF radiation. ICNIRP has clearly

mentioned only thermal effects

It is amply clear from the studies of

ICNIRP/WHO that there is no

established relationship between

radiation from mobile towers and

cancer/tumour.

These case studies of Usha Kiran

building and Riddi Park quoted by

Prof. Girish Kumar highlights EMF

radiation as the only environmental

factors while ignoring all other factors

which might be significant. Committee

opined that, without any conclusive

evidence, such examples could be a

matter of further analysis rather than

saying that EMF radiation was an

environmental factor in these case

studies for causing cancer/tumour.

Page 38 of 70

Committee felt that such selective

highlighting of EMF radiation, as the

only environmental factor, may cause

unfounded fear and scare among

public and should be avoided in the

absence of any conclusive evidence.

Members have further questioned the

assumption of Prof. (Dr.) Girish

Kumar that cancer can develop

during a short period of exposure to

EMF radiation to a new born baby

during pregnancy in 9 months time

whereas as per the present

findings, latency period for

developing cancer in human being

is 10-15 years. Similarly

assumptions of Prof. (Dr.) Girish

Kumar that brain tumor has

developed during 4 months of

exposure to EMF radiation is also

not acceptable as the latency

period is much higher.

Conclusion:

It is noted by the Committee that

measured EMF radiation power

levels from cell tower have not

been quoted by Prof. (Dr.) Girish

Kumar in this example while

ignoring all other factors which

might be relevant. Also no peer

reviewed conclusive analysis has

Page 39 of 70

been presented by him. This

makes the case study highly

misleading and objectionable and

at best be termed as anecdotal.

Several epidemiological studies

have been reported in Paris, Spain,

Netherlands, Germany, Brazil,

Austria, Israel, Egypt, Swedish,

India, etc. (this was mentioned by

one of the members, file is attached -

List os studies of adverse afects of

RFR).

In my first newsletter, given to all

committee members, I had given

several cases of cancer clusters in

various cities of India.

However, committee report did not

include it for the reasons best

known to the members.

6 International Exposure Standards for

some of the countries (about 12 only)

was presented that the radiation norms

vary from 2w/m2 to as low as

0.00001w/m2

The examples taken by Prof. (Dr.)

Girish Kumar are from very few

countries and some are the examples

of small local bodies/counties in a

country. China and Russia have

adopted 0.1W/m2 (=100 m1W/m2)

and these are not small countries.

These are isolated examples and as

per information available, these


Page 40 of 70

norms are not even legally binding in

some of these countries.

It is worthwhile to mention that most

of the countries in the world have

adopted ICNIRP limits as

recommended by WHO.

Moreover, India is among the very

few countries who have adopted

precautionary approach and have

adopted much lower norms than rest

of the world which is 1/10th of ICNIRP

recommended EMF radiation limit.

India has adopted 1/10th of ICNIRP

limits as an abundant precaution.

Switzerland has adopted 0.04W/m2.

Austria (Salzburg) has adopted

0.001W/m2. Bio-Initiative proposed

0.0001 W/m2 but committee chose to

ignore these.

Conclusion:

India’s prescribed limits for

radiation are already much lower

than most of the countries in the

world. Therefore, there is no need

to further reduce the limits without

conclusive studies by International

standards bodies and India’s own

conclusive research and findings.

There is an urgent need to reduce

Page 41 of 70

the limit from health point of view.

Bio-Initiative proposed 0.0001 W/m2

but committee chose to ignore these.

7 Analysis of certain studies done in few

countries have been quoted by Prof. (Dr.)

Girish Kumar. These include Spain,

Israel, Germany, Sweden, Brazil and

India

It is noted by the committee that only

few select studies, many of them

possibly without any peer review,

have been picked in the example

given in the presentation by Prof (Dr.)

Girish Kumar, simply to buttress his

own point of view. Whereas

International Organisations like

United Nation’s WHO conduct peer

review of the independent studies

done by an individual or a country

and have taken into account

approximately 25,000 studies over

past 30 years from all over the world.

Several epidemiological studies

have been reported in Paris, Spain,

Netherlands, Germany, Brazil,

Austria, Israel, Egypt, Swedish,

India, etc. In my first newsletter,

given to all committee members, I

had given several cases of cancer

clusters in various cities of India.

Conclusion:

The studies quoted by Prof. (Dr)

Page 42 of 70

Girish Kumar, therefore, may be

relevant for conducting further

peer review at international level

for appropriate correlation and can

not be relied upon at this stage

without any conclusive evidence.

The Bio-Initiative Report 2012 is prepared by 29

scientists and health experts from 10 countries

and was uploaded in Jan. 2013 to create

awareness. It is an update of Bio-Initiative Report

2007, which was published by Bio-Initiative

Working Group that looked at more than 2,000

peer reviewed studies documenting bio-effects

and adverse health effects from EMF exposures.

They recommended safe radiation density of 1

milliwatts/m2 for outdoor and 0.1 milliwatts/m

2

for indoor continuous exposure.

Bio-Initiative 2012 assessed 1800 new research

papers (from 2006 to 2011) and mentioned that

Bio-effects are clearly established and occur at

very low levels of exposure to electromagnetic

fields and radiofrequency radiation. Even at 0.03

milliwatts/m2, researchers have reported

headaches, concentration difficulties and

behavioral problems in children and adolescents;

and sleep disturbances, headaches and

concentration problems in adults.

8 Comparison of Automobile industry with

Mobile industry was explained to the

members by comparing air pollution with

radiation.

Comparison of cigarette with cell phones

was also explained

Committee deliberated on the issue

and noted that studies are available

to link outdoor air pollution with

human health. IARC, an agency of

WHO, in its press release dated 17th

October 2013 has already classified

the ‘Outdoor air pollution’ as

carcinogenic to humans as ‘Group 1’

which is the highest category. Hence,

Page 43 of 70

it is highly inappropriate to compare

outdoor air pollution with EMF

radiation as no conclusive evidence

has emerged so far regarding ill

effects from EMF radiation on human

health.

Similarly, ill effects of cigarette

smoking can not be compared with

mobile phone use. There is no

conclusive evidence about the ill

effects of mobile phone use at the

most stringent SAR levels as adopted

in India.

(No conclusive evidence does not

mean any evidence. Committee

deliberately tried to play with words).

To reiterate, Committee noted that

India has already adopted a more

precautionary approach in fixing the

present norms as mentioned below:

(i) For Cell Towers:

1/10th of ICNIRP limit as the

prescribed limit of EMF

radiation from cell tower.

This limit is very high for

24x7 exposure. It should be

Page 44 of 70

less than 0.1 mW/m2.

(ii) For Mobile Phones:

SAR values adopted in

India are 1.6Watt/Kg

averaged over 1gm tissue,

which are most stringent.

The limit of 1.6W/Kg is

good for 6 minutes with a

safety margin of 3 to 4. So,

people should not use cell

phone for more than 10 to

30 minutes depending upon

the SAR value.

Conclusion:

The Committee observed that it is

incorrect to correlate automobile

industry or smoking with EMF

radiation. Such type of comparison

of incomparable situation creates

misconception and unfounded

anxiety among the people.

People understand automobile

pollution and smoking hazards, so to

correlate, this example was given.

Also, worst automobile pollution is felt

when a person is on crowded road

and smoking effect is felt when

person smokes. However, cell tower


Page 45 of 70

radiation is 24x7, which is absorbed

by every human being, birds, animals,

trees, plants, etc.

2. B. 1. During discussions, Prof. Girish Kumar also referred to the report of 24 faculty

members of various IITs which was issued by Prof. Ashok Jhunjhunwala of IIT

Madras in September 2013. Prof. Ashok Jhunjhunwala is a board member of one

of telecom companies, Prof. Girish has informed the committee members that he

personally does not agree with this report.

As Prof. Girish Kumar referred to the report issued by Prof. Ashok Jhunjhunwala

of IIT Madras, a member of this committee Dr. Prof. S. N. Sinha circulated

photocopy of a statement issued in September 2013, by Prof. Ashok

Jhunjhunwala IIT Madras, on behalf of 24 faculty members of various IITs on

effects of EMF radiation on health. (Annexure-IV)

Committee noted that this report included Prof. Abhay Karandikar (presently

HOD, Electrical Engineering Deptt. IIT Bombay) and two other faculty members

from IIT Bombay (from the same Electrical Engineering Department of IIT

Bombay to which Prof (Dr.) Girish Kumar belongs). (Three faculty members

mentioned here have not worked on microwaves, antennas, microwave heating

principle, biological effects, etc.)

Gist of their recommendations is as follows:

“1) We consider the recommendations of DoT, Government of India, to be

sensible and based on the international best practices at this point in time. They

should be implemented strictly, including ensuring radiation norms are met at

windows, balconies and roof-tops near cell-towers. At this stage, there is no

further knowledge available that warrants a change in the recommendations.

Results of new research, as well as complaints from citizens, should be carefully

Page 46 of 70

examined on a continuous basis, and the recommendations modified as found

appropriate. However, caution should be exercised to avoid ad-hoc decisions

regarding restrictions on tower locations as long as they meet the stringent

guidelines, and to avoid unnecessary panic and fear among the citizens.

2) We further would like to see the following:

i) Creation of a public database, where all study reports (pro and con)

on the health implication of EM radiation should be placed. Also, all

arguments in favour and against putting higher restrictions on

radiation should be placed. The site should become a public

repository for all information, so that it can be analyzed on a

continuous basis. This should be supervised by a committee of

academicians.

II) As the bit-rates required on Internet increases and usage of

Internet in India increases, there will be more and more usage of

wireless (especially in the absence of adequate wired infrastructure

in India). Further higher bit-rates imply higher RF energy

transmitted if energy per bit remains the same. India needs to

evolve a focused scientific program to develop technological

solutions to reduce transmitted energy per bit required by a factor

of ten in the next five years and by a factor of hundred in the next

ten years. Difficult though these goals may appear today, focused

scientific research should get us there.

III) There is a need to conduct on a continuous basis multiple scientific

studies on the subject of short-term, mid-term and long-term health

implications of EM radiations. The studies should be reviewed and

thereafter published. DST, DBT, ICMR etc may fund such studies.

Disclosure: All of us have been working on R&D in telecom for 5-35

years. From time to time, some of our work has been funded by

Page 47 of 70

various Govt. agencies and by telecom operators (mostly through

telecom centre of Excellence at IITs). Some of us have been

consultants to telecom manufacturing and operations companies

and have also been independent Board members of these

companies. We sign the statement solely in our professional

capacity and as responsible citizens.”

Most of the Committee members have been working in Industry

sponsored Telecom Center of Excellence and some of them have

been board members of telecom companies. Also, majority of them

have worked on baseband, signal processing, network protocol,

etc. and have not worked on microwaves, antennas, microwave

heating principle, biological effects, etc.)

Conclusion:

The Committee feels that the recommendations of the 24 faculty

members of various IITs appropriately addresses the concerns

regarding EMF radiation.

(it does address the concerns regarding health hazards of EMF

radiation. They completely ignored several thousands of scientific

papers, which have reported several health hazards)

2.B.2. Committee, after having carefully gone through the reports as submitted

alongwith with the petition and the points raised by Dr. Prof. Girish Kumar,

observes that the issues raised by him, about the dangerous ill effects of

EMF radiations on human health from cell towers and mobile phones, are

an exaggeration, and not based on any conclusive scientific evidence.

The dangerous ill effects of EMF radiations on human health from cell towers and

mobile phones, are based on large number of scientific evidences. My

report to DOT contained 200 references and Bio-Initiative reports have

given 3800 scientific references.

Page 48 of 70

2. C. In view of the direction of the Hon’ble High Court, Committee also took note of

the present status of the implementation of the accepted recommendations of

Inter-Ministerial Committee on EMF radiation issued vide OM dt 17th Nov 2011

by DoT. Following is the present status of the implementation of the Office

Memorandum:

Inter-Ministerial Committee on EMF radiation had also reported hazards of EMF

radiations on human health from cell towers and mobile phones,

Mobile Handset

S/N Recommendations Status of implementation of guidelines

I SAR level for mobile handset shall

be limited to 1.6 watt/ kg ,

averaged over a 6 minutes period

and taken over a volume

containing a mass of 1 gram of

human tissue.

Guideline has been issued to all Mobile

Manufacturers vide para 3(i) of DoT letter

no 18-10/2008-IP dt 25 January 2012, to

be effective from 1st Sept 2013.

II SAR level shall be displayed on the

handset.


Manufacturers vide para 3(ii) of DoT letter

no 18-10/2008-IP dt 25 January 2012,

effective from 1st Sept 2013.

III All cell phone handsets sold in the

market in India shall comply with

relevant BIS standards and shall

be with hand free devices.


Manufacturers vide para 3(iii) of DoT letter

no 18-10/2008-IP dt 25 January 2012,

effective from 1st Sept 2013 to adhere to

SAR limits of 1.6 watts/Kg.

IV SAR value information of the

mobile handsets shall be available

on the manufacturer’s web site & in

the handset’s manual. The

information on SAR values shall be

made available to the consumer at

the point of sale.


Manufacturers vide para 3(iv) of DoT letter

no 18-10/2008-IP dt 25 January 2012


Page 49 of 70

V Mobile hand set manufactured and

sold in India or Imported from other

countries shall be checked for

compliance of SAR value.


Manufacturers vide para 3(v) of DoT letter

no 18-10/2008-IP dt 25 January 2012,

effective from 1st Sept 2013 for importers

to adhere to the SAR limits.

VI The manufacturers in India shall

provide self-declaration of SAR

Value of the handset. In respect of

imported handset from other

countries, the manufacturers apart

from self-declaration of SAR shall

specify the SAR information in their

documents for verification by

appropriate authority. Suitable

amendment in the Indian

Telegraph Rule under Indian

Telegraph Act 1985 shall be

enacted for strict compliance.


Manufacturers vide para 3(vi) of DoT letter

no 18-10/2008-IP dt 25 January 2012,


Suitable amendment in the Indian

Telegraph Rule under Indian Telegraph

Act 1985 under consideration for

enactment.

VII Manufacturer’s mobile handset

booklet shall contain the following

safety precautions:

a) Use a wireless hand-free system (headphone, headset) with a low power Bluetooth emitter.

b) Make sure that cell phone has a low SAR

c) Keep your calls short or send a text message (SMS) instead. This advice applies especially to children, adolescents and pregnant women.

d) Use cell phone when the signal quality is good.

e) People having active medical implants should keep the cell phone at least 15 cm away from the implant.


Manufacturers vide para 3(vii) of DoT letter

no 18-10/2008-IP dt 25 January 2012,


Page 50 of 70

VIII List of SAR values of different

mobile phones shall be uploaded

on DoT/TEC website.

The format for such uploading is under

finalization. The uploading of SAR values

will be done in due course.

It should be also mentioned that the limit of 1.6W/Kg is good for 6 minutes

with a safety margin of 3 to 4. So, people should not use cell phone for more

than 10 to 30 minutes depending upon the SAR value. Also, it should be

written that on May 31, 2011, WHO has classified cell phone as possible

carcinogen (Class 2B) after Interphone study reported 5,117 brain tumor

cases for heavy users.

Mobile Base Station (Cell Tower)

S/N Recommendations Status of implementation of

guidelines

IX The exposure limit for the Radio

Frequency field (Base Station Emissions)

lowered to 1/10th of the existing exposure

level as under:

Type of

exposure

Frequency

range

Power

Density

(Watt/Sq.

mtr)

General

Public

400-

2000MHz

f/2000

2-300 GHz 1

Licenses of the Telecom Service

Providers were amended on

30/12/2011 revising the EMF

radiation norms as recommended.

The revised norms became

effective w.e.f 1st September 2012.

This limit is very high for 24x7

exposure. It should be less than

0.1 mW/m2. In the densely

populated areas, micro towers (low

transmitting power) should be

installed instead of macro towers

(high power transmitting antennas).

X Provision shall be made for continuous

online monitoring and display of radiation

level in mobile network frequency range at

The feasibility of this

implementation is being examined.

On preliminary study it appears

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spacing: Multiple 1.15 li

Formatted: English (United States)

Page 51 of 70

prominent places in metro/cities and online

data transfer to the central server.

that the continuous monitoring may

be feasible at limited locations only

and it will serve only a limited

purpose.

XI The mobile service providers apart from

self-certification for compliance of radiation

norms on EMF exposure shall measure

the radiation level in mobile network

frequency range of prominent places and

display it for information of general public.

The service providers should have mobile

unit for its measurement wherever

necessary

This is linked to the para X above.

XII A national data base with the information

of all base stations, their emission

compliance status (i.e. compliant/non-

compliant) shall be created and made

available in DoT website for public

information

Such a database is under

development. It will be

implemented after pilot trials in few

states.

XIII Uniform guidelines to be formulated at

national level to enforce restrictions on

establishment/setting up of BTS towers

Advisory Guidelines for State

Governments for issue of

clearance for installation of Mobile

Towers have been issued by DoT

which are effective from

01.08.2013 These guidelines are

not sufficient to protect people from

24x7 radiation from cell towers.

XIV An appropriate framework to be created

for structural safety clearance for towers

set up on roof-tops.

This aspect has been taken care in

Para 4A(IV) of Advisory Guidelines

for State Governments for issue of

clearance for installation of Mobile

Towers have been issued by DoT

which are effective from

01.08.2013

XV In the Master Plan of towns and cities the

location for installation of mobile towers

shall be identified in consultation with the

Appropriate action in DoT is under

way.

Page 52 of 70

Ministry of Urban Development

XVI New technology low power transmitters

shall be installed with in-building solutions

for the future expansion of telecom

network in the country

Government has announced

‘National Telecom Policy 2012’ in

May 2012 and one of the strategy

has been envisaged as:

“5.9.

To promote use of In-Building

Solutions (IBS) and Distributed

Antenna Systems (DAS)….” while

planning Telecom network.

Further, the service providers are

mostly using these technologies as

per requirement/feasibility to

provide coverage inside multi

storey buildings.

XVII Long term scientific research related to

health aspect of EMF radiation exposure

from multiple antennas of a shared

infrastructure sites and associated

technologies in India shall be encouraged

Science and Engineering Research

Board (SERB) under Department

of Science and Technology has

constituted a Expert Committee /

Task Force in September 2013, to

evaluate the R&D proposal on the

possible impact of EMF radiation

exposure from mobile towers and

handsets on life (humans, living

organism, flora & fauna and

environment) and related

initiatives.

In addition, Indian Council of

Medical Research is also

conducting a multi-disciplinary

cohort study in Delhi and National

Capital Region to find out adverse

effects of Radio Frequency

Radiation, if any, emitted from cell

phone on adult Indian population.

(These studies will delay the

Page 53 of 70

implementation of stricter radiation

norms. Already, there are

evidences of health hazards given

in 1000's of papers. So, strict

guidelines must be implemented

immediately and study can go on in

parallel for Indian conditions.

XVIII A document "Radio waves and safety in

our daily life" in regional languages

indicating various Dos and Don'ts related

to mobile phone users clarifying various

myths regarding deployment and use of

radio waves shall be created for enhanced

customer awareness and to be given to

the customer at the point of sale by the

mobile service provider.

The document has been issued

and is placed on the DoT website.

The document must be modified to

inform dangers of overuse of cell

phones and 24x7 exposure to high

cell tower radiation.

2.D. Discussions on implementation of various guidelines in India and research

work being carried out in the area of “Health Effects from EMF Radiation”

1. Summary of discussion about EMF norms adopted in India:

(i) Committee has noted that WHO in its Facts sheet no. 304 of May 2006

has stated that:

“International exposure guidelines have been developed to provide

protection against established effects from RF fields by International

Commission on Non-Ionizing Radiation Protection (ICNIRP,1998) and the

Institute of Electrical and Electronics Engineers (IEEE,2005).

National authorities should adopt international standards to protect their

citizens against adverse levels of RF fields. They should restrict access to

areas where exposure limits may be exceeded.”

All the above are outdated. In 2011, WHO reported cell phone as possibly

carcinogen (Class 2B). What is the point in mentioning earlier reports? Also,

there are growing evidences of health hazards in the last few years (as cell

Page 54 of 70

phone/tower radiation is cumulative in nature). There are 1000's of scientific

papers reporting health hazards but committee chose to ignore.

(ii) ICNIRP guidelines have made, inter-alia, following recommendations:

a. EMF radiation from tower :

ICNIRP has recommended the limit from cell phone tower as

“f /200 watt per meter square”

where ‘f’ is frequency in MHz.(for 400-2000 MHz)

b. EMF radiation from mobile handset:

ICNIRP has recommended Specific Absorption Rate (SAR) level of

mobile handset as 2 watt per /per kg averaged over mass of 10 gm

of tissue.

(iii) IEEE guidelines have, inter-alia, made following recommendations:

EMF radiation from mobile handset:

IEEE has recommended Specific Absorption Rate (SAR) level of

mobile handset as 1.6 watt per /per kg averaged over mass of 1 gm

of tissue.

(iv) Committee notes that India has adopted f/2000 watt per meter square as

the EMF radiation limit from cell phone tower which is 1/10th of the ICNIRP

recommended limit whereas majority of the countries around the world

have adopted the limits prescribed by ICNIRP.

(v) Similarly, Committee further notes that with reference to the EMF radiation

from mobile handset India has adopted more stringent recommendations

of IEEE rather than ICNIRP recommended limits which are 1.6 watt per kg

averaged over mass of 1 gm of human tissue, as against the ICNIRP

Page 55 of 70

recommended limit of 2 watt per kg averaged over mass of 10 gm of

human tissue.

(vi) Committee also further notes that though there are some isolated

examples of a few countries or counties / local bodies on a country

adopting lower radiation norms from cell phone towers but as per the

available information as far as SAR values are concerned these countries

have adopted the norms of ICNIRP.

(vii) The Committee also noted that in case of EMF radiation level from

BTS/Tower become too low at a location, the EMF radiation power from

mobile phone, which is in kept near to head, increases.

(viii) India is among the very few countries to adopt the precautionary approach

and probably the only country to adopt stringent SAR values for mobile

handsets alongwith 1/10th of ICNIRP recommended norms as limit for

radiation from cell phone towers, as an abundant precaution. These

guidelines are not sufficient to protect people from 24x7 radiation from cell

towers. It must be reduced to 0.1 mW/m2. In other countries, even though

they adopted ICNIRP guidelines, they use micro towers (low transmitting

power) In the densely populated areas instead of macro towers (high

power transmitting antennas). In the FCC document OET56, on Page 21,

it is mentioned that in urban area, radiated power of 0.5 -1W or less is

commonly used. It should be also mentioned that for handsets, the limit of

1.6W/Kg is good for 6 minutes with a safety margin of 3 to 4. So, people

should not use cell phone for more than 10 to 30 minutes depending upon

the SAR value. Also, it should be written that on May 31, 2011, WHO has

classified cell phone as possible carcinogen (Class 2B) after Interphone

study reported 5,117 brain tumor cases for heavy users.

2. Implementation of EMF Norms and discussion about the research

reports:

Page 56 of 70

(i) Committee also notes that enforcing compliance of the recommended

norms is an important aspect in limiting the EMF radiation exposure and

keeping general public areas around the tower safe.

(ii) In order to implement the EMF radiation norms, DoT has prescribed a

procedure to be followed by the telecom service providers. To oversee the

implementation, DoT through its 34 field units, known as TERM units,

takes self-certificates for compliance of EMF norms by the operators and

conducts regular audit of the EMF radiation exposure from the mobile

towers as per the prescribed procedure. (Self certification is not good.

Also, audit of only 10% of sites is done).

(iii) For violation of the EMF norms by the telecom operators, if any, penalties

are levied and BTSs may also be shut down in case violation persists.

(iv) Committee also noted that DOT has already audited physically more than

80,000 BTSs so far all over the country and violation of prescribed EMF

norms was found in 152 BTSs out of which 127 BTSs were in Mumbai

alone. Appropriate action has already been taken by DOT in these cases.

The list of violators must be uploaded and what action has been taken.

(v) In order to increase the deterrence, Department of Telecom, recently on

20th November 2013, has made the compliance norms more stringent.

The penalty for non-compliance to EMF norms by mobile operators has

been increased from Rs. 5.00 lakh to Rs. 10.00 lakh. This penalty is

applicable per occasion per mobile operator per site if the tower site is

shared by more than one operator and is applicable to all the operators

sharing the tower site. (Norms must be reduced)

(vi) EMF radiation limits from cell tower and mobile handsets have been

prescribed by DoT taking into account both thermal and non-thermal/

biological effects of EMF radiation. This is not correct as stated above.

Page 57 of 70

(vii) Committee notes with satisfaction the efforts made by Department of

Telecom in adopting the most precautionary approach for limiting the EMF

radiation from mobile towers in addition to adoption of most stringent SAR

level for mobile handsets in India. Further the penalty on non-compliant

telecom service providers has been doubled to Rs. 10.00 lakh per site per

occasion per operator. (Norms must be reduced as stated earlier)

(viii) Committee also noted that in reply to a online question, WHO on 20.9.13

has mentioned:

“…………Because exposure to the radiofrequency (RF) fields emitted by

mobile phones is generally more than a 1000 times higher than from base

stations, and the greater likelihood of any adverse effect being due to

handsets, research has almost exclusively been conducted on possible

effects of mobile phone exposure.

THIS IS VERY IMPORTANT, it implies that base station radiation is

1/1000 of mobile phones. We have measured radiation density of many

mobile phones, when they are in the talk mode, and it is around 100

mW/m2, so 1/1000th will be 0.1mW/m2. Thus, the safe radiation norm

should be around 0.1mW/m2 and not 450mW/m2. This is also the

recommendation of Bio-Initaitve Reports, Austrian Medical Association,

and based on my interaction with 100's of people who sufferred due to

high cell tower radiation. People have reported headaches, sleep disorder,

memory loss, joint problems, infertility, mis-carriages, cardiovascular

problems, cancer, etc.………………………

………………………

WHO has further concluded that While an increased risk of brain tumours

from the use of mobile phones is not established, the increasing use of

mobile phones and the lack of data for mobile phone use over time

periods longer than 15 years warrant further research of mobile phone use

and brain cancer risk. In particular, with the recent popularity of mobile

Page 58 of 70

phone use among younger people and, therefore, a potentially longer

lifetime of exposure, WHO has promoted further research on this ground

and is currently assessing the health impact of RF fields on all studied end

points.

This information is in public domain on the website of WHO. However, a

copy of the reply to the online question by WHO is enclosed as

Annexure-V. The second paragraph should be read in the light of

first paragraph.

(ix) Committee, after going through the reply of an online question by WHO

dated 20.9.2013, notes the finding of WHO that exposure to the

radiofrequency (RF) fields emitted by mobile phones is generally more

than a 1000 times higher than from base stations and there is greater

likelihood of any adverse effect being due to handsets. And that research

has almost exclusively been conducted on possible effects of mobile

phone exposure.

Committee is of the opinion that in the light of WHO report and the fact

that India has already adopted precautionary approach by reducing the

limit of EMF exposure from both mobile towers and mobile phones,

present prescribed norms are adequate.

Present norms are as mentioned below:

a) For Cell Towers:

1/10th of ICNIRP limit as the prescribed limit of EMF radiation from cell

tower. This still very high

b) For Mobile Phones:

SAR values adopted in India are 1.6 Watt/Kg averaged over 1gm tissue,

which are most stringent. limited use must be emphasized.

Page 59 of 70

The prescribed EMF exposure limits in India are well within the safe limits.

no, these limits are high for 24x7 exposure

(x) WHO in its Fact Sheet No. 193 of June 2011 (ANNEXURE-VI), has stated

that there are some indications of an increased risk of glioma for those

who reported the highest 10% of cumulative hours of cell phone use,

although there was no consistent trend of increasing risk with greater

duration of use. The researchers concluded that biases and errors limit the

strength of these conclusions and prevent a causal interpretation. Based

largely on these data, IARC (an agency of WHO) has classified

radiofrequency electromagnetic fields as possibly carcinogenic to humans

(Group 2B), a category used when a causal association is considered

credible, but when chance, bias or confounding cannot be ruled out with

reasonable confidence.

WHO has further stated that a large number of studies have been

performed over the last two decades to assess whether mobile phones

pose a potential health risk. To date, no adverse health effects have been

established as being caused by mobile phone use. They found limited

evidence and that's why it was classified as Possibly carcinogen (Class

2B). If there was no adverse health effect, they would have classified as

Class 3 or 4.

Committee also noted that, in fact, substances, mixtures and exposure circumstances

classified by the International Agency for Research on Cancer (IARC) as ‘Group 2B’,

inter-alia, include coffee, Aloe vera (whole leaf extract), Pickled vegetables (traditional in

Asia), Talc-based body powder etc. (source IARC Monographs) Let me ask, how many

times people eat pickles in a day, may be, maximum 2 to 3 times; how many times people drink

coffee, may be maximum 2 to 5 cups of coffee per day. Similarly, using cell phones for up to 10

to 30 minutes may be safe depending upon SAR value of the cell phone. Interphone study

released in May 2010 reported 5,117 brain tumor cases and stated that people who use cell

phones for 30 minutes per day over a duration of 8 to 10 years, have doubled to quadrupled

chances of getting brain tumor, and that's why it was classified as Class 2B. Use of cell phones is

a personal choice but what about people who live in the vicinity of cell towers, they are exposed

to the radiation 24x7.

Page 60 of 70

(xi) Committee also deliberated in detail the various studies and information

circulated through email by various Members of the Committee. These

studies include ICNIRP report, Bio-Initiative report, FCC guidelines, report

of Health Protection Agency (United Kingdom), EMF exposure limit

comparison and various other studies related to effects of EMF radiation

on human health.

(xii) With regard to Bio-Initiative report 2007, committee noted the statement

issued in year 2009 by the Committee on Man and Radiation (COMAR)

which is a technical committee of the Engineering in Medicine and Biology

Society (EMBS) of the Institute of Electrical and Electronics Engineers

(IEEE), an international standard making body. COAMAR is primarily

working in the area of biological effects of non-ionizing electromagnetic

radiation, including radiofrequency (RF) energy. explaination is given

below.

COMAR submitted a statement in 2009 on BioInitiative report titled: “COMAR Technical Information Statement: Expert reviews on potential health effects of radiofrequency electromagnetic fields and comments on the BioInitiative Report”. (Annexure-VII) Extract of this statement is as below: “This report summarizes the conclusions from several major reports and comments on the markedly different conclusions in the BioInitiative Report (abbreviated BIR below). Since appearing on the Internet in August 2007, the BIR has received much media attention but, more recently, has been criticized by several health organizations (see Section titled “Views of health agencies about BIR”). COMAR concludes that the weight of scientific evidence in the RF bioeffects literature does not support the safety limits recommended by the BioInitiative group. For this reason, COMAR recommends that public health officials continue to base their policies on RF safety limits recommended by established and sanctioned international organizations such as the Institute of Electrical and Electronics Engineers International Committee on Electromagnetic Safety

and the International Commission on Nonwhich is formally related to the World Health Organization.”

Further, committee also noted that Indian

(ICMR), on critical examination of the Bio

observed that the report is not based on multi disciplinary weight and there

is no balanced reflection of the current state of scientific knowledge.

However, further study is needed to arrive at a conclusion about the

potential health effects of EMF radiation.

It was also noted that, WHO, after studying approximately 25,000 studies over past 30

years has concluded that current evidence does not confirm the

consequences from exposure to EMF radiation.

WHO report. The Bio-Initiative Report 2012 is prepared by 29 scientists and health experts from 10 countries

and was uploaded in Jan. 2013 to create awareness. It is an update of Bio

published by Bio-Initiative Working Group

effects and adverse health effects from EMF exposures. They recommended safe radiation density of 1

milliwatts/m2 for outdoor and 0.1 milliwatts/m

Bio-Initiative 2012 assessed 1800 new research papers (from 2006 to 2011) and mentioned that Bio

clearly established and occur at very low levels of exposure to electromagnetic fields and radiofrequency radiation.

Even at 0.03 milliwatts/m2, researchers have

in children and adolescents; and sleep disturbances, headaches and concentration problems in adults. Public safety

standards are 1,000 – 10,000 or more times higher than levels now comm

studies to cause bio-effects.

Cell phone/tower industry criticized the report citing other reports and references. However, according to me,

Initiative Reports of 2007 and 2012 are the most authentic reports on this subject, giving references of 3800 research

papers, written by more than 1000 scientists, reviewed by equally large number of experts and published in the

prestigious journals.

Also, Guidelines of Austrian Medical Association adopted on 3rd March 2012 in Vienna

(xiii)

Page 61 of 70

and the International Commission on Non-Ionizing Radiation Protection, which is formally related to the World Health Organization.”

Further, committee also noted that Indian Council of Medical Research

(ICMR), on critical examination of the Bio-initiative 2012 Report, has



further study is needed to arrive at a conclusion about the

health effects of EMF radiation.


years has concluded that current evidence does not confirm the existence of any health

consequences from exposure to EMF radiation. This statement is taken

Initiative Report 2012 is prepared by 29 scientists and health experts from 10 countries

and was uploaded in Jan. 2013 to create awareness. It is an update of Bio-Initiative Report 2007, which was

Initiative Working Group that looked at more than 2,000 peer reviewed studies documenting bio


for outdoor and 0.1 milliwatts/m2 for indoor continuous exposure.

2012 assessed 1800 new research papers (from 2006 to 2011) and mentioned that Bio


, researchers have reported headaches, concentration difficulties and behavioral problems


10,000 or more times higher than levels now commonly reported in mobile phone base station

Cell phone/tower industry criticized the report citing other reports and references. However, according to me,

Reports of 2007 and 2012 are the most authentic reports on this subject, giving references of 3800 research


nes of Austrian Medical Association adopted on 3rd March 2012 in Vienna

Ionizing Radiation Protection, which is formally related to the World Health Organization.”

Council of Medical Research

initiative 2012 Report, has



further study is needed to arrive at a conclusion about the


existence of any health

This statement is taken from older

Initiative Report 2012 is prepared by 29 scientists and health experts from 10 countries

Initiative Report 2007, which was

ed at more than 2,000 peer reviewed studies documenting bio-


2012 assessed 1800 new research papers (from 2006 to 2011) and mentioned that Bio-effects are


reported headaches, concentration difficulties and behavioral problems


only reported in mobile phone base station

Cell phone/tower industry criticized the report citing other reports and references. However, according to me, Bio-

Reports of 2007 and 2012 are the most authentic reports on this subject, giving references of 3800 research


nes of Austrian Medical Association adopted on 3rd March 2012 in Vienna are: Formatted: Font: 11 pt

Formatted: Font: 11 pt

Formatted: Font: (Default) Arial,Arial, 14 pt

Page 62 of 70

(xiv) Further, committee also noted that DoT has issued “Precautionary

guidelines for the mobile users” to increase public awareness,. In addition,

DoT has also published advertisements in National

& Regional Newspapers for creating awareness among public for ensuring

safety from EMF radiations emitted from Mobile Towers & handsets.

Further, for the information of the general public, a hand book on “Mobile

Communication - Radio Waves & Safety” has also been issued. These

documents are available on the website of DoT also. (Annexure-VIII) some

of the guidelines issued by DOT are confusing and convey there are no

health hazards, whereas there are 1000's of papers, which have reported

health hazards.

2.E. Other Discussions:

(i) Committee noted that as part of professional ethics, a practice is being followed

by all the professionals before publishing any report/ newsletter in public domain to

make a disclosure about their commercial business interest or the commercial business

interest of their close relatives and family members. Committee noticed that Prof. (Dr.

Girish Kumar) has not made any such disclosure about the studies being conducted by

him/ reports submitted by him or on the newsletters being published by him on the issue

of health effects from EMF radiation. Though Prof. (Dr.) Girish Kumar has agreed to

submit a proper disclosure on his work related to EMF radiation initially but he later on

refused to give any such disclosure. However, Prof.(Dr.) Girish Kumar has stated that

the information given in his newsletter be considered as his disclosure. The other

members of the Committee feels that he should have specifically disclosed his family’s

commercial interest in companies involved in manufacturing / dealing with EMF

shielding products. In my second newsletter on cell phone/tower radiation hazards and

solutons, it is clearly mentioned on Page 5 under point 6. Father - Daughter Team -

Radiation Solutions

The cell operators and their associates say that Prof. Girish Kumar is telling about

harmful effects of radiation because his daughter, Neha Kumar, has a company named,

"NESA Radiation Solutions Pvt. Ltd", which sells radiation shielding solutions.

My reply was: On every forum and at all the places, I always say adopt better radiation

norms and reduce the transmitted power. If they reduce the transmitted power, then

Page 63 of 70

who will need the shielding solutions? This newsletter has been openly circulated to

large number of people, so I have openly disclosed the facts.

(ii) Committee wants to highlight that Dr. (Prof.) Girish Kumar had circulated

an email to all the committee members, casting aspersions and ascribing

bias against them which was strongly objected to by the members (copy of

minutes of first meeting of the committee are enclosed as annexure-I).

Most of the members were of the view that it amounts to undermining the

premier institutions and disagreed with Prof. Girish Kumar’s prejudiced

stance at the very outset. Prof. (Dr.) Girish Kumar refused to attend and

participate in the meetings of the committee despite pursuance by DOT

and did not attend the first meeting. It is worth mentioning that while

formulating the committee, nominations were asked from the Head of the

organizations and based on the nominations, so received, the committee

was constituted in line with the directions of the Hon’ble High Court.

I have given below the email sent by me:

Dear Shri Rama Shankar,

Recd. your following email with the attachement reagrding Meeting Notice of the

committee constituted on the direction of Honourable High Court Allahabad on

25.09.2013 at 3.30 PM at Sanchar Bhawan.

I saw the names of the 13 committee members. I am extremely disappointed

to see the names, majority of whom are pro DOT norms (in a way favourable

to high radiation emitted by cell operators) of 450 mW/sq.m to

1000 mW/sq., whereas people are having health problems even at a level

Page 64 of 70

of 1 mW/sq.m within 5 to 10 years. According to Bio-Initiative report

2012, for 24x7 exposure, safe level must be less than 0.1 mW/sq.m.

For example (the serial numbers are according to the file attached: 1. Shri Sirohi - from

DOT

4. Prof. Ranjan Mallik, IITD - pro cell operators 5. Prof. SN Sinha, IIT Roorkee - says no

health problems

7. Dr. RS Sharma, ICMR, Delhi - will say we are carrying out studies,

and will give the results in 2 years.

10. SS Kohli, DST, Delhi - I had attended expert committee meeting organized by him

and chaired by DST Secretary on July 3, 2012. There were

13 people in the meetined and 4-5 people mentioned about various health hazards and

yet it was concluded there is no conclusive evidence. In their subsequent expert

committee meeting, I was not even invited.

11. UK Srivastava, TEC - known to favour high radiation norm

12. Nitin Jain - from DOT

13. Atul Kumar Chaudhary - from DOT

Thus, out of 13 members, 8 are known to favour DOT norms (high radiation). based on

my prior experience mentioned above, I do not want to attend

this closed door meeting, where my view-points will be outnumbered.

I can come if and only if, it is an open door meeting, where media and

concerned people are invited, who have sufferred due to high cell tower

radiation, and then everybody's view points are noted and recorded.

I am willing to give presentation at the HC, Allahabad in front of

the honourable Judge, lawyers and concerned citizens.

With regards.

(Girish Kumar)

Page 65 of 70

It can be noted from the report, committee members proved my apprehension as right. The

language used by the committee members is not appropriate. Instead of trying to come

out with a scientific and balanced report to protect, people, birds, animals, plants, trees,

etc., the entire focus of the members turned out to prove Prof. Girish Kumar wrong. Is

this the way to convene a very prestigious meeting, which was formed due to Allahabad

HC.

After the first meeting, one of the members called me that I should have come as other people

are planning to file contempt of court against me. I am a law abiding citizen, so I agreed

to attend these meetings. However, it has been the most horrifying experience for me

to attend subsequent meetings, where one or other members constantly tried to

interrupt me, ridicule me, and so on.

(iii) Committee also noted that Prof. (Dr.) Girish Kumar in his newsletter of

October 2013 while responding to some allegation has admitted to his

commercial interest in the family business of ‘radiation shielding

solutions’.The committee observed that his daughter Ms. Neha Kumar is

selling ‘Radiation Shielding Solutions’ through her company named “NESA

Radiation Solutions Pvt. Ltd.” The members of the Committee noted that

on one hand he is spreading misinformation & creating misconceptions

and unfounded apprehensions in the mind of public by sensationalizing

and blowing out of proportion the effects of EMF radiation, on other side

he is promoting his family’s business on related products (which do not

even follow any National/International standards) thus throwing

professional ethics to the winds.

Again I want to mention:

On every forum and at all the places, I always say adopt better radiation norms

and reduce the transmitted power. If they reduce the transmitted power,

then who will need the shielding solutions?

This newsletter has been openly circulated to large number of people, so I have

openly disclosed the facts.

Formatted: Font: (Default) Calibri, 11

pt, Not Bold

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line: 0 cm, Line spacing: Multiple 1.15

li, Don't adjust space between Latin

and Asian text, Don't adjust space

between Asian text and numbers

Page 66 of 70

3. Observations and Recommendations of the Committee for taking necessary

precautions with respect to EMF radiation from mobile towers and mobile

phones.

3.A. OBSERVATIONS:

I. The Committee has carefully examined all the submissions of the petitioner,

through the presentation of Prof. (Dr.) Girish Kumar. On the basis of scientific

evidences, studies and reports available, it has been found that there is no

conclusive evidence about the stated dangers of EMF radiation from mobile

BTS tower as raised by the petitioner. First of all, no conclusive evidence does

not mean no evidence. I provided them 1000's of references but committee

decided to ignore these due to the reasons best known to them.

As regards the possible health hazards of EMF radiation from mobile phones,

WHO has concluded in its Fact Sheet No. 193, year 2011 that a large number of

studies have been performed over the last two decades to assess whether

mobile phones pose a potential health risk. To date, no adverse health effects

have been established as being caused by mobile phone use. Further studies

are ongoing in different parts of the world to assess possible health effects of

mobile phone exposure. WHO classified cell phone as possibly carcinogen

(Class 2B). It did not classify it as Class 3 or 4.

In addition, in reply to an online question, WHO on 20th September, 2013 has

mentioned that Studies to date provide no indication that environmental

exposure to RF fields, such as from base stations, increases the risk of cancer

or any other disease. Further, it is also mentioned that Scientists have reported

other health effects of using mobile phones including changes in brain activity,

reaction times, and sleep patterns. These effects are minor and have no

apparent health significance. More studies are underway to try to confirm these

findings. Only second paragraph of the WHO reply is included. First part

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mentions that exposure to the radiofrequency (RF) fields emitted by mobile

phones is generally more than a 1000 times higher than from base stations and

there is greater likelihood of any adverse effect being due to handsets. THIS IS

VERY IMPORTANT, it implies that base station radiation is 1/1000 of mobile

phones. We have measured radiation density of many mobile phones, when

they are in the talk mode, and it is around 100 mW/m2, so 1/1000th will be

0.1mW/m2. Thus, the safe radiation norm should be around 0.1mW/m2 and not

450mW/m2.

II. The Committee also took note of the actions taken by the Department of

Telecommunication in view of the accepted recommendations of the Inter-

ministerial Committee. It has been observed by the Committee that the

Department has taken adequate steps to impose stricter precautionary limits for

EMF radiation from mobile towers as well as from the mobile phones. Much

more stricter norms must be implemented.

III. The committee observed that DoT has taken adequate steps in regard to

granting of permission for siting of mobile towers in its recent guidelines to State

governments and TERM cells in different licence service areas effective from

01-08-2013. Further, stricter ‘SAR’ values have been specified for mobile

phones being sold in India, effective from 01-09-2013. DOT has not taken

adequate steps to safeguard people.

IV. Also, in order to make the deterrence stronger, the penalty for violation of

prescribed stricter EMF norms from BTS tower by telecom service providers has

been increased from Rs. 5 Lakhs to Rs. 10 Lakhs per BTS, per incidence per

operator w.e.f. 20th November, 2013.

V. Presently some organisation including ICMR, SERB are making efforts to

scientifically investigate and mitigate the possible health hazard potential of

EMF radiation keeping in view the country specific aspects such as population

density, gGeographical condition, Indian society context and the eco-system

etc., there is a need to further speed up the scientific studies/research in order

to generate credible scientific data/evidences. These studies are extremely

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essential in order to assess the further need to improve the EMF exposure

norms based on the credible scientific evidences. These studies will take

several years. Stricter radiation norms must be implemented immediately based

on 1000's of studies available. Study may be done in parallel but after reducing

the norms.

VI. The Committee repeatedly requested Prof. Girish kumar to provide scientific

evidence / data in support of his claims. However, he did not provide any

scientific documents in support of his arguments and stated that the he does not

agree with the conclusions of the committee. He was also given ample

opportunity to question the scientific rationale behind the conclusion /

observations of the committee but he did not. I had provided them list of 200

papers in my DOT report and also list of 1000's of papers, which reported health

hazards. Most of the time, they will produce other papers, which mention there

are no problems. In all the meetings, it appeared that majority of the members

are the mouth pieces of cell tower industry, who is trying to safeguard their

business interest.

3.B. RECOMMENDATIONS:

I. The Department of Telecom should continue the extensive audit of the self -

certificates being submitted by the Telecom Service Providers in order to ensure

compliance to the prescribed stricter norms of EMF radiation from BTS tower.

Why self certification?

II. The Department of Science and Technology and Indian Council of Medical

Research (ICMR) should carry out / facilitate extensive studies, on the Indian

conditions with special focus on prolonged use of mobile phone, to conclusively

determine sensitivity of EMF Radiation / possible health hazard risk of EMF

radiation, which at present is not proven. These Indian specific scientific studies

should aim at generating scientifically credible data and evidences by involving

Ministry of Science and Technology, ICMR, Ministry of Environment & Forest,

DoT and other relevant organisation. The Government of India should make

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available funds to ensure extensive long term/short term research and studies on

possible health effects of EMF radiation on humans. It is a good idea, however,

we must adopt lower norms immediately and studies can be taken in parallel.

III. Department of Telecom has already taken measures to create awareness among

public by issuing “Precautionary guidelines for the mobile users” and publishing

advertisements in National & Regional Newspapers for ensuring safety from EMF

radiations emitted from Mobile Towers & handsets for the information of the

general public.

A hand book on “Mobile Communication - Radio Waves & Safety” has also been

issued by Department of Telecom. These measures, inter-alia, include:

(i) Frequently asked questions (FAQ)

(ii) Myths and Facts

(iii) Precautionary guidelines for Mobile Users

These precautionary guidelines, inter-alia, include the following precautions:

• Keep distance – Hold the cell phone away from body to the extent possible

• Use a headset (or ear bud) to keep the handset farther from your head. • Do not press the phone handset against your head.

• Use a wired headset

• Limit the length of mobile calls. • Use text as compared to voice wherever possible.

• Put the cell phone on speaker mode. etc.

According to the committee members, if there are no health hazards, then why take

above precautions. This means that they agree there are problems and want to use

precautions.

Committee recommends that there is a need to step up effort by DOT to spread

public awareness and allay undue apprehensions in regard to possible health

effects of EMF radiation. This can be done through print media/electronic media

and other communications channels and tools along with conducting market

research / survey, workshops and seminars etc. Awareness should be created to

warn people about overuse of cell phone and living in the vicinity of high cell

tower radiation.

IV. Annual discussion, meetings/seminars should be conducted by the Government

by inviting experts from various academic and research institutions for continual

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evaluation of scientific evidence published worldwide with an aim to monitor the

progress in research on the effects of EMF radiation.

V. In order to get latest updates on EMF radiation related issues, DoT should

actively participate in the deliberations of various International standards bodies,

including WHO, involved in the study of EMF radiation.

Department

of Telecom should create national EMF web portal to provide public

access to the status of compliance, of the prescribed norms, of all BTSs/ mobile

towers in the country and related relevant information.

. Awareness must be

created to inform people about health hazards of overuse of cell phones. Also,

micro towers (low power transmitters) should be installed in densely populated

are, so that people living in the vicinity of towers are not exposed to high cell

tower radiation.

VI.

(Dr. S.N. Sinha) (Professor, IIT Roorkee)

Member

(Dr Ajit Kumar Chaturvedi) (Professor, IIT Kanpur)

Member

( Dr Ranjan Mallik) (Professor, IIT Delhi)

Member

(Dr. Vivek Tandon) (AIIMS, New Delhi) Alternate Member

(Dr. Girish Kumar) (Professor, IIT, Mumbai)

Member

( Dr. R.C. Murthy) (Chief Scientist,IITR Lucknow)

Member

(Dr. R. S. Sharma) (ICMR, New Delhi)

Member

(Dr. Ajoy Chakraborty) (Professor, IIT Kharagpur)

Member

(Shri S. S. Kohli) (SERB New Delhi)

Member

(Shri U. K. Srivastava) (DDG, TEC, DoT)

Member

(Shri Nitin Jain) (DDG CS, DoT)

Member

(Shri Rama Shankar Ram) (Director (CS-TP), DoT)

Alternate Member Convener

(Shri S. S. Sirohi) (Sr. DDG (TERM), DoT)

Chairman

Presentations & Public Speaking

Prof. Girish Kumar's comments on "DOT Report for Allahabad HC" on EMF Radiation and Health