• 24 MAR 14
    • 0

    Have your say: SCENIHR extends its public submission deadline

    Notice from Cindy Sage on behalf of the Bioinitiative Working Group:

    The BioInitiative Working Group sent the below letter on March 7th to SCENIHR – DC SANCO about the limited public consultation input – and received their reply (also below) on March 13th.

    We’ve been able to open the comment process to email comments – rather than posting in the narrow format on-line. It opens the process to much more detailed (longer) assessments.
    And, to extensive referencing for our analysis, which is much needed.

    You can share this with others who have our same concerns about the process, and how it’s been opened up now.

    *******************************************************************************************************************************

    7 March 2014
    Mr. Ladislav Miko
    Mr. Robert Vanhoorde
    Mr. Michael Walsh
    SANCO.DDG2.03 – Relations with Agencies and Advisory Groups
    Via email
    Re: Preliminary Opinion on Potential Health Effects of Exposure to Electromagnetic
    Fields (EMF)
    Gentlemen,
    The BioInitiative Working Group is in the process of reviewing the Preliminary Opinion on Potential Health Effects of Exposure to Electromagnetic Fields (EMF).
    The public consultation period requires submittals by April 16, 2014. As we read it, the instructions from SCENIHR designate a format that limits comment to 2500 characters (or by our estimate, about 500 words). No email or postal mail comments may be submitted separately.

    This letter requests SCENIHR to allow more detailed comments on the 211 page draft report. We respectfully request that our full comment be accepted and reviewed as part of the public consultation process. Otherwise, meaningful scientific and public health expert comment would be excluded. It basically defeats the purpose of soliciting public consultation if comments are limited to 2500 characters of analysis, conclusions and suggested revisions.

    Further, the SCENIHR hearing in Athens at the end of March also limits testimony to two minutes per participant. This proces further limits valuable comments and dissuade experts from participating in the public consultation process. Valuable input to the SCENIHR document will be lost as a result.

    Thank you for your consideration.
    Respectfully submitted on behalf of the BioInitiative Working Group by:
    Cindy Sage, MA and David O. Carpenter, MD
    Co-Editors, BioInitiative 2012 Report

    ********************************************************************************************

    SCENIHR’s reply:

    Dear Ms Sage,
    Dear Mr Carpenter,
    Subject: Reply to your letter on the preliminary Opinion on Potential Health Effects of Exposure to Electromagnetic Fields (EME)

    I am replying to your letter of 7 March 2014 addressed to Mr. Ladislav Miko and Mr. Robert Vanhoorde, as it is my Unit which provides the secretariat to the Scientific Committees.

    I would like to thank you and the Bioinitiative Working Group for participating in the ongoing public consultation on electromagnetic fields and potential health effects thus
    showing interest for the work carried out by the European Union in this particular field. Please allow me to clarify the procedures in place for this public consultation. You
    mention that there is limited space to express your comments on the on-line form. Please note that there are 2500 characters for each chapter/subchapter of the form used for the
    public consultation, which reflect the list of contents of the preliminary opinion. In total, the system allows you to comment on some 90 different chapters/subchapters, and for
    each of these you can add an unlimited number of files of maximum 1 Mb each. However, if you still feel that you need more space, you can send additional comments to
    SANCO-C2-SCENIHR@ec.europa.eu

    I would also like to draw your attention to the fact that, due to the complexity of this preliminary opinion and our commitment to engage in an open dialogue with relevant
    stakeholders, we decided to prolong the period of public consultation by four weeks. This preliminary opinion was published on the 4th of February and will remain open
    until the 16th of April 2014
    (normally preliminary opinions remain open for public consultation for only six weeks).

    With regard to your comment about the limited time given to each scientist registered to speak in the public hearing, the two minutes slot is due to the large number of
    participants who have registered for this event and the need to ensure equal treatment to each speaker.

    At the moment we have some 70 participants, each of them has the right to at least introduce himself/ herself and present his/her scientific contribution. This accounts for
    2,5 hours without considering SCENIHR experts’ reply (if needed). If some participants decide not to take the floor, we will adjust the schedule accordingly and will allow more time to all the participating speakers.

    We look forward to receiving your comments on the preliminary opinion and to meeting you in Athens at the public hearing.

    END

    Access the public consultation form here

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