European Union Council Recommendation on EMF

Abstract

On 12 July 1999, the Council of the European Union formally adopted a Recommendation ` ... on the limitation of exposure of the general public to electromagnetic fields (0 Hz to 300 GHz)'. The scientific origins of this Recommendation lie with the International Commission on Non-Ionizing Radiation Protection (ICNIRP)'s `Guidelines for limiting exposure to time-varying electric, magnetic, and electromagnetic fields (up to 300 GHz)' (1998 Health Phys. 74 494-522). In some respects, these are similar to the NRPB Guidelines (1993 Doc. NRPB 4 no 5). Both are based on well-understood acute effects of fields (primarily induced currents and heating); both examine the suggestions that chronic exposures to lower levels of fields may be harmful, but regard the evidence as insufficient. They set `basic restrictions' on induced current density, specific absorption rate and power density (depending on frequency), and give `reference levels' for field strengths which serve as a guide to whether the basic restriction is likely to be exceeded or not. ICNIRP's basic restrictions for occupational exposures are similar to the NRPB's. However, ICNIRP gives separate basic restrictions for exposure to the public, which are lower than the occupational values by factors of, typically, 5. The ICNIRP Guidelines have been the subject of considerable comment and discussion since their publication, including letters on the subject in five subsequent issues of Health Physics. This prompted ICNIRP to issue a `Response' (1998 Health Phys. 75 438-9). Among other things, this Response makes one key change: it states that, at power frequencies, the basic restrictions on induced current should apply just to the central nervous system and not to the whole head and trunk as originally stated. This is likely to make a significant difference to the practical impact, as the field required to induce a given current in the central nervous system is higher than to induce the same current in the periphery of the trunk. Within the European Union, there had previously been moves (which ultimately came to nothing) to introduce a Directive that would cover occupational exposures. The present Recommendation concerns exposures to the public, not occupational exposures. The various treaties governing the Union do not appear to allow a Directive in the area of public health. The Recommendation originated with Directorate General V of the Commission, was debated in the European Parliament, scrutinised by an expert group of the Health Council, and ultimately adopted by the Council. The numbers in the Recommendation are identical to the public limits from ICNIRP. Thus, from 4 Hz to 1 kHz, the basic restriction is an induced current density of 2 mA m-2, and from 100 kHz to 10 GHz the main basic restriction is a whole-body SAR of 0.08 W kg-1, both of which are a factor of 5 lower than the corresponding NRPB figures. At 50 Hz (the power frequency in the UK) the stated reference levels are 5 kV m-1 for electric fields and 100 µT for magnetic fields. These pre-date the change in the basic restriction to the central nervous system only, so are now largely irrelevant. Unfortunately, numerical modelling of induced currents in the body, whilst advancing all the time, is not yet accurate enough to indicate with any certainty what fields do correspond to the basic restriction. In the text surrounding the numbers, the key phrase is that the Council recommends Member States to implement measures `in respect of sources or practices giving rise to electromagnetic exposure of the general public when the time of exposure is significant ... ', considering both `the risks and the benefits in deciding whether action is required or not'. There is no guidance on what constitutes `significant'. There is in fact no requirement on Member States to take any action at all on what is only a Recommendation. Member States will thus have to make a judgment on what action, if any, is appropriate, and under what circumstances. The NRPB, commenting on the ICNIRP Guidelines, has said that its existing UK advice already provides sufficient protection, and that `any health benefits to be obtained from further reductions in exposure have not been demonstrated' (1999 Doc. NRPB 10 no 2). The House of Commons European Scrutiny Committee have said `if there are no demonstrable health benefits, we cannot see any reason why additional costs should be incurred' (22nd Report 1999). The Government now have three years before they are asked to report to the Commission on what action, if any, they have taken.