Commentary from Don Maisch:
ICNIRP states about it’s forthcoming “15 Years On: Reviewing The Past And Looking Forward” workshop (last message) that:
“Social impact on radiation protection philosophies is increasing and there seems to be a need to reconsider basic principles for standard setting in comparison with other environmental risk factors such as ionising radiation. Now is an appropriate time for ICNIRP to review its achievements, strategy, philosophy and challenges for the future to be relevant to an ever-changing world. The program of the Workshop will allow considerable scope for participants to provide their [insights] on how a 21st century ICNIRP should function.” (1)
According to ICNIRP, their September 2008 workshop will be to review its strategy and philosophy in setting standards. For those who live in hope that this will finally result in a better “health based” standard for ELF-EMF, think again. A very possible, if not probable, outcome for this meeting may be a proposal to actually increase the ICNIRP ELF exposure limits by a factor of three, based on Australian recommendations.
Some people on this list are aware that Australia is close to finalizing a new exposure standard for extremely low frequency magnetic and electric fields which significantly departs from ICNIRP. This new standard is a product of the Radiation Health Committee, part of the Australian Radiation Protection & Nuclear Safety Agency (ARPANSA). The most notable feature of this standard is an increase in the overall Australian allowable ELF exposure by a factor of three. Thus the new reference levels for magnetic fields (for 50 Hz) increase to:
• 3,000mG (300uT) from the previous ICNIRP based 1,000mG (100uT) for residential exposures.
• 15,000mG (1,500uT) from the previous ICNIRP based 5,000mG (500uT)
The basic restrictions in the proposed Australian limits only apply to acute ‘instantaneous exposures’ and not chronic exposures. However, in the real world, the new limits will inevitably come to be quoted as a reference point to somehow infer safe exposures . Why worry about the possibility of 4mG doubling the risk of childhood leukaemia if the ’safe’ benchmark exposure limit is a whopping 3000mG for your home or 15,000mG for your workplace? Whenever official limits are used as reference levels in controversial power-frequency EMF issues the limitations of these standards are never spelt out, but the inference is given that they are safe limits, below which no health effects exist.
After rejecting the epidemiological literature, the basis for the new Australian standard’s basic restrictions is to “prevent the occurrence of magnetophosphenes in the sensitive retinal tissue”. These are visual flashes sometimes experienced by people, such as by patients undergoing MRI scanning due to excitation of the optic nerve. I call it the “sparkle standard”.
Why such a radical departure from ICNIRP’s hegemony which has long been claimed to represent the pinnacle in expert EMF science? Why the dismissal of all that epidemiological and other evidence, as detailed in the Bioinitiative report? This radical departure would only have been with close co-operation of ICNIRP, considering the inter-relationship between ARPANSA members and ICNIRP. Note that Colin Roy from ARPANSA is presenting on the second day of ICNIRP’s September conference, which would suggest that ICNIRP is not too concerned over Australia’s seemingly departure from their established “basic principles for standard setting”?
May I suggest that Australia’s seemingly divergence from ICNIRP is no divergence at all but a clever ruse by ICNIRP to generate support to increase their own guideline limits as well. Australia is the testing ground. If they can get away with the increase in Australia without significant public and trade union opposition, the next step would be to try it on internationally. This is why the September ICNIRP conference is so important – and why it needs wider attendance than the usual suspects, such as industry representative Repacholi and his faithful band of deniers.
In order to understand why such a drastic increase in allowable ELF exposure limits is being proposed first in Australia and next the world, one must be aware of the implications of one of the European Union’s Physicial Agent Directives (PAD), specifically Directive 2004/40/EC.
This Directive, based on the existing ICNIRP limits, is designed to protect the health and safety of workers from “established health risks” from exposure to electromagnetic fields which by law must be incorporated within the legislation of all member states by 2008. The EC Directive (and ICNIRP), however, have become a major concern for the Magnetic Resonance Imaging (MRI) medical community and manufacturers because, to quote from “medicalphysicsweb” in relation to new generation high-power MRI machines, “there are a number of situations in which MRI workers exceed the proposed exposure-limit values for low-frequency, time-varying magnetic fields”. (2)
In other words, both the 2004 EC directive and the ICNIRP rationale used in establishing its exposure limits have created an “enormous detrimental effect” (3) on MRI with a flow-on for the healthcare industry that routinely uses MRI in diagnosis.
An earlier concern for the MRI manufacturers/users sector was that the proposed limit for static magnetic fields of 2T (Tesla) in the Directive would have halted the development and use of new high-field MRI scanners, especially considering that some now operate up to 3T. Last minute lobbying by the MRI sector had this provision deleted from the final Directive.
Now the MRI sector is concerned that the Directive’s limits (and therefore ICNIRP’s as well) are over-restrictive for the development of new high power MRI machines. The problem is not for the patient who only has a brief exposure while being scanned but for MRI machine operators and service technicians because MRI workplace practices place the operator within the gradient coil magnetic field, specially when the operator frequently needs to be able to reach the patient. To quote again from “medicalphysicsweb”: “Put simply, the PAD [EC Directive] will kill off interventional MRI in Europe, at an early stage of its development and before its value has been properly established.” (4)
The relevance for this, specific to Australia, is that these new high-powered MRI machines are increasingly being imported and used in the country. It was interesting that at the last ARPANSA consultative committee meeting MRI diagnostic representatives were in attendance and were very insistent that their needs be catered to.
To argue for the elimination of MRI technology because employees could be receiving excessive EMF exposures is totally out of the question. The ‘Catch-22’ situation is that enforcement of the ELF limits in the European Directive (and ICNIRP) could result in the return to the use of ionizing radiation technology in its place, and that would obviously not be advisable for either the MRI operator or the patient.
MRI is an indispensable tool in today’s society but why not take a precautionary approach and take action to protect MRI workers against being exposed to EMF levels in excess of the current EC Directive and ICNIRP limits? This would include shielding work areas and instigating safe work practices to keep employees outside high field areas during MRI operation. Such measures may come with a considerable extra expense but it looks like the preferred, no cost option is just increasing the standard limits to suit the needs of the MRI industry and then just tell the operators not to be concerned because their exposures are under the safe limits!
While the MRI controversy goes on behind the scene, what is lost in the discussion is the proper and rational reason for having “health based” standards in the first place. It seems that the only thing that shifts entrenched views on EMF standards, such as that of ICNIRP, is not better biological science but only when existing limits become a barrier to the deployment of some new technology.
So what about the problem of 4mG (0.4uT) increasing the risk of childhood leukaemia? Well, unfortunately, when you weigh up the increased risk for children chronically exposed to 4 mG against the enormous financial investment in the new-generation MRI technology by the medical fraternity – and the massive profits to be gained by its use, unfortunately the children lose out.
Undoubtedly there are real benefits in high power MRI in better diagnosis of diseases, especially for early detection of cancer, but this benefit should not over-ride public health protections, especially protections against cancer. One could be very cynical and suggest that one ‘unintended consequence’ of ICNIRP’s standard setting philosophy is to assure a pool of future customers who will be in need of MRI diagnosis for their cancers….
This is the dilemma facing our standard setters and is apparently the real reason for the proposed increased exposure limits in the Australian ELF standard. This is why a ‘ health based’ EMF exposure standard based on anything other than economic considerations is virtually impossible under the current ICNIRP regulatory regime.
The other issue lost in the MRI /standards controversy is what about the possible hazards to people working with MRI machines? Not only the operators but the technicians who routinely service the scanners, even apparently climbing in them, with the magnets energized to save on “costly ramp-downs of the magnets”. This is another economic decision that saving costs for the hospital take precedence over employee health and safety considerations. Considering that MRI operators and service technicians can be exposed to both static and time-varying magnetic fields in excess of the existing ICNIRP limits, does simply increasing the limits automatically make them safe from these repeated workplace exposures?
The organizers of the September ICNIRP conference no doubt hope all goes smoothly with no troublesome questions being raised to spoil their inbred festivities. If the draconian Australian proposal is accepted for ICNIRP’s consideration then any chance of real health based ELF standards will be set back for generations.
In other words – this is an event not to be missed!
August 10, 2008
1) ICNIRP Announcement, http://www.icnirp.org/WshopProtection.htm, Accessed August 8, 2008
2) Watching the directives: big trouble for MRI, medicalphysicsweb, http://medicalphysicsweb.org/cws/article/opinion/27418 , Accessed August 9, 2008
3) Prudence, practicality and the future of MRI, medicalphysicsweb, http://medicalphysicsweb.org/cws/article/opinion/25661 , Accessed August 9, 2008
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