Testimony of Michael Repacholi

Final modification on: 7/22/08

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Recognition that the electromagnetic fields (EMFS) from high-voltage powerlines were a putative cause of human disease entered the public consciousness in the mid-1970s as a result of public hearings held by the New York State Public Service Commission. In the ensuing 30 years the financial, scientific, moral, and legal issues associated with the issue of health risks from powerline EMFs came into sharper focus, as did the possibility of other forms of EMF pollution, and different kinds of EMF-related scientists emerged. Some had an honest desire to understand how EMFs affect the body and to learn the truth about the health risks they caused, and to do so with whatever degree of certainty or reliability was possible, irrespective of whom it might displease. Robert Becker is the prototype of such a scientist. Unfortunately, many scientists fell far below his benchmark.

Some of those who failed were political opportunists who happened to be near or in authority when a wave of concern arose and carried them to temporary prominence. David Carpenter in New York and Christopher Portier at the NIH are two examples. Typically, opportunists are well-trained scientists who are ignorant of EMF biology; they strut on the EMF stage for a while, and then turn their attention to the next expedient issue that comes before their agency.

Another kind consisted of those who produced whatever scientific data pleased the company funding their work. The EMF scientists who worked for the Electric Power Research Institute or Battelle Pacific Northwest are examples, particularly Richard Phillips. Their work consisted of the production of data that could be spun by industry experts testifying in court.

A third species of lamentable EMF scientist consisted of those who specialized in the art of spinning; two examples are Granger Morgan and Leeka Kheifets.

A fourth type of sub-par scientist, exemplified by Meike Mevisen and Jukka Juutilainen, are persons respected for the quality of their science, and who are bold enough to publish articles indicating that powerline EMFs are capable of producing biological effects, but who are careful never to allow attachment of societal relevance to their work. Thus they are useful to the power industry as window dressing on blue-ribbon committees because they lack the desire or aptitude to stare down the powerful interests that secured their appointment in the first instance.

At the bottom of the barrel is the EMF scientist who functions as a brainwasher to deceive the public, innocent young and old alike, into giving themselves cancer and other diseases. There is no purer example of such a man than Michael Repacholi. He is at the end of a historical line of change that must be recognized before science can once again resume its task of finding the best truth possible.

Repacholi acts as if he were invested as regards the natural world with powers like those exercised by priests over souls. Amazingly, people believe the daydream that he has the ability to identify true and certain knowledge regarding EMFs. He has perpetuated this myth, with almost no critical questioning. Not only is there the myth of Repacholi’s wisdom according to which he can see through the mist into the truth of things, but also the myth that absolute truth about exactly what EMFs do and how they do it can be discerned if only we looked in the correct fashion. He has succeeded in hiding any sense of the complexity of nature, so the ordinary person does not understand that the best EMF science could ever hope to do was to produce imperfect and uncertain understanding, and to achieve knowledge about EMFs that was only somewhat better than a guess.

Repacholi has staged innumerable dramas—committees, commissions, meetings, seminars—where the experts he appointed said only pleasant things about EMFs and offered reassuring risk assessments. My goal here is to expose Repacholi for the scientific fraud that he is.

Repacholi’s career began in earnest in 1990 when he was hired by a power company in his native Australia. He gave extensive testimony to the effect that the EMFs from the powerline would be perfectly safe. I have reproduced his testimony in its entirety because it is the finest example I know of someone who thinks he “knows” what “truth” is, and who therefore sees no need to engage in critical discourse.

Repacholi’s text is also worth reading to gain an understanding of the technical arguments that infect the legal discourse of the EMF health issue. Like the arguments of Euthydemus or Dionysodorus, Repacholi’s testimony is often base and disgusting, consisting of nothing more than plays on words or half-truths. But sometimes his testimony is like the speech of Protagoras or Gorgias, clever and well thought-out. In all cases, however, Repacholi’s testimony is sophistic because it is not intended to get at the best truth possible, but simply to win the court case.


No. 40308 of 1989




Deponent: Michael Repacholi

Sworn: 11.7.90

Solicitors & Notaries,
Level 59, MLC Centre,
19-29 Martin Place,
SYDNEY, N.S.W. 2000.
DX: 105
Tel: 229.8765
Ref: SI-i 656827 AYD

On the 11th day of July, 1990, I MICHAEL REPACHOLI of 25 Statenborough Street, Leabrook, South Australia, Chief Scientist for the Royal Adelaide Hospital solemnly and sincerely affirm and declare that:

  1. I have been asked to report on the following matters:
    1. an examination of the scientific debate and the preferred scientific conclusions that may properly be drawn as at February 1987, February 1988 and currently with respect to the effects of 50Hz electric and magnetic fields;
    2. the process of standard setting, with particular reference to the process by which the world Health Organisation (WHO) and the International Non-Ionizing Radiation Committee (INIRC) of the International Radiation Protection Association (IRPA) have derived guidelines for exposure to 50/60 Hz electric and magnetic fields and the purpose of such guidelines and reports;
    3. the adequacy, as viewed from my area of expertise, of the environmental impact statement under challenge in these proceedings and the documentary information considered by the determining authority before making its decision to proceed with the Mt Piper-Marulan transmission line; and
    4. reply to the comments of the applicant’s experts within my area of expertise.
  2. I have set out my comments according to the following structure:




  3. I hold a B.Sc. in Physics from the University of Western Australia 1965; an M.Sc. in Radiation Biology from the University of London, England 1969; and a Ph.D. in Biology from the University of Ottawa, Canada 1980.
  4. I have over 25 years experience in the area of protection against radiation hazards. Through my background and experience I have a wide appreciation of radiation hazards and the principles underlying the development of human exposure standards. My curriculum vitae is attached as Appendix 1.
  5. I have been involved in the drafting of codes of practice for the control and safe use of various forms of radiation. As part of my position with the Royal Adelaide Hospital I chair the Radiation Safety Committee (since 1983) and am the Radiation Safety Officer for the Hospital (since 1983).
  6. I am the non-ionizing radiation specialist for the Radiation Health Committee of the National Health and Medical Research Council.
  7. I have been a member of the International Radiation Protection Association (IRPA) International Non-ionizing Radiation Committee (INIRC) since 1978 and have been Chairman of this Committee since April, 1988. Since 1980 I have been involved in reviewing the scientific literature related to possible adverse health effects of exposure to 50/60 Hz fields for preparation of International Labour Office and World Health Organisation reports developed in conjunction with the IRPA/INIRC.
  8. The International Radiation Protection Association is a non-governmental organisation representing nearly all the national radiation protection societies in the World. It provides a focus for international debate on radiation safety issues.
  9. IRPA initiated activities concerned with non-ionizing radiation by forming a Working Group on Non-Ionizing Radiation in 1974. This Working Group later became the International Non-Ionizing Radiation Committee (IRPA/INIRC), at the IRPA Congress held in Paris in 1977. The IRPA/INIRC reviews the scientific literature on non-ionizing radiation and makes assessments of the health risks of human exposure to such radiation.
  10. Based on the Environmental Health Criteria Documents (eg WHO 1984, 1987) developed in conjunction with the World Health Organisation (Geneva), the IRPA/INIRC recommends guidelines on exposure limits, drafts codes of safe practice, and works in conjunction with other international organizations to promote safety and standardization in the non-ionizing radiation field. These documents are drafted to give objective, critical, unbiased reviews of the literature by an international group of experts with expertise covering areas including basic research, medicine, physics, engineering, biology, epidemiology and risk analysis. The purpose of the documents is to inform health authorities, regulatory agencies and other institutions on the current status of bioeffects research, gaps in knowledge, possible effects on human health and provide guidance on assessment of risks from occupational and general public exposure to non-ionizing radiation (including 50/60 Hz electric and magnetic fields).
    Comment 1 by Andrew Marino

  11. The present composition, country of origin and major areas of the IRPA/INIRC Committee are as follows:
    Dr M H Repacholi (Chairman) Australia Biophysics/Risk Analysis
    Dr J Bernhardt F R Germany Biophysicist/Regulator
    Dr B Bosnjakovic Netherlands Biophysicist/Regulator
    Dr L Court France Biophysicist/Researcher
    Dr P Czerski USA (recently deceased) Medicine/Researcher
    Dr M Grandolfo Italy Physics/Regulator
    Dr B Knave Sweden Medicine/Epidemiologist
    Dr A McKinlay UK Physics/Regulator
    Dr M Shandala USSR Medicine/Researcher
    Mr D Sliney USA Physics/Researcher
    Dr J Stolwijk USA Epidemiologist/Researcher
    Dr M Stuchly Canada Engineer/Researcher
    Dr L Szabo Hungary Medicine/Regulator
    Mme A Duchenne France Chemist/Risk Analysis
    (Scientific Secretary)
    Dr H Jammet France Medicine/Risk Analysis
    (Chairman Emeritus)
  12. The IRPA/INIRC not only has the full range of disciplines to conduct in depth reviews of the scientific literature, it has people with opposing views so issues are fully discussed and consensus reached.
  13. I have been a member of 9 World Health Organisation task groups reviewing non-ionizing radiation health effects criteria, (including 3 on 50/60 Hz fields), and have chaired three of these task groups (see Appendix 1). In addition I have been the drafting author or co-author of various World Health Organisation and International Labour Office reports on non-ionizing radiation health criteria, I have been a scientific editor of many of the final reports. I was the author of the first draft of the WHO Environmental Health Criteria 69 on Magnetic Fields, published in 1987.

    It is important to note that to produce documents for WHO, the IRPA/INIRC prepares the first draft in conjunction with various experts from around the world. For example, the initial draft for the WHO (1984) was prearepd by Dr W R Adey (USA), Dr A Sheppard (USA), Dr N G Shandala (USSR), Dr V Akimenko (USSR), Dr P Czerski (then from Poland) and Mr J Villforth (USA).

    The drafts go through editorial review and are then sent out by WHO to their focal points in all major regions of the world, to institutions of health in most countries, to expert institutions as well as individual researchers and experts in the field. An editorial review then incorporates all comments and any additional scientific literature important for a health risk analysis. The penultimate draft is then subjected to an international task group made up of experts worldwide. The task group reviews the text in detail and produces a series of recommendations and conclusions covering the status of research, identifying gaps in knowledge, gives a health risk assessment of exposure to NIR fields, provides guidance on the setting of human exposure limits and safety measures. Finally, the document is language edited prior to publication by WHO.
  14. I am currently the President of the Australian Radiation Protection Society (ARPS)—the Australian Society of radiation protection professionals dedicated to ensuring workers and the general public are not exposed to ionizing or non-ionizing radiation levels in excess of acceptable standards. ARPS is the Australian representative society of the IRPA.
  15. I have been a peer reviewer for many grant applications for research (eg. National Occupational Health and Safety Commission), for post graduate theses and for a number of scientific journals including Health Physics (the major radiation protection journal in the world), Radiation Protection in Australia (the journal ot the Australian Radiation Protection Society), and Australasian Physical and Engineering Sciences in Medicine (the journal of the Australasian College of Physical and Engineering Sciences in Medicine).
  16. I have been employed as Chief Scientist for the Royal Adelaide Hospital since January 1983. The position is at the level of Assistant Medical Director.
  17. I have been employed as follows:
    Health and Welfare Canada, Radiation Protection Bureau in 1971, and as Head of the Non-Ionizing Radiation Section Ottawa, Canada 1975-1983;
    Medical Physicist with the Saskatchewan Cancer Commission, Regina, Canada 1969-1971;
    Physicist with the State X-Ray Laboratory, Dept. of Health, Perth, Western Australia 1965-1968; and
    Summer student employee with the Australian Atomic Energy Commission, Lucas Heights, NSW 1964-1965.
  18. I have published more than 110 scientific articles, mainly in the area of non-ionizing radiation effects, health hazard assessment and standards on human exposure limits.
  19. I have expertise in radiation protection, having over 25 years experience reviewing scientific literature and performing surveys and research into non-ionizing radiation biological effects. This work is performed primarily to develop limits of exposure to radiation in the occupational and general population. I have worked at the national and international levels to evaluate scientific literature and develop human exposure standards, codes of safe practice and device emission standards.

    I am not a researcher. However I have conducted research previously as part of my doctorate thesis and am familiar with many of the experimental methods used to conduct research. My main area of expertise is in standards’ development which has meant that I have had to review the scientific literature many times to identify biological effects that relate potentially to adverse health effects in humans. In conducting such reviews, I look at all aspects of research including the in vitro, in vivo, animal experiments and epidemiological studies. It is necessary to look at all aspects of the literature to identify if there are established trends in the literature where all aspects of research lead to the same conclusion. In conducting such reviews, I need to discriminate between various scientific reports to determine whether they are providing information which is new or they are reproducing previously reported results. Publication in peer reviewed scientific literature is normally accepted as a higher standard of presentation than abstracts that are presented at scientific meetings or reports that are not published in the scientific literature. I have gained significant expertise in this area since becoming a member of the International Non-Ionizing Radiation Committee of the IRPA where Committee members are from a whole range of disciplines as described in this affidavit and resulting discussions on various aspects of the literature have assisted me greatly.
  20. A full resume of my employment record, work experience, international activities, national activities, professional society membership, consulting/advisory positions held and abstracts, publications and reports published by me contained in Appendix 1. I have placed an asterisk (*t) beside articles in peer reviewed journals and have placed the mark “(+)” next to references appropriate to this case. ⇑Back to Top


  21. Before I address the specific issues, it will be of assistance to briefly outline the physical characteristics of 50/60 Hz fields, the ways some have suggested they interact with tissue, where 50/60 Hz fields are with respect to the whole electromagnetic spectrum and the differences between the fields or radiations in the major subsections of the spectrum.

    2.1 What Are 50 Hz Electric and Magnetic Fields

  22. Electric power from electricity generating stations is distributed to homes and factories via high voltage (HV) transmission lines which are stepped down in voltage by transformers to lower voltages, and finally down to voltages that are used in the mains (electrical outlets), as shown in Figure 1.
    Comment 2 by Andrew Marino
    Fig01 FIGURE 1 Diagram of a power distribution system in Victoria (SECV, 1989)
  23. 50 Hz electric and magnetic fields exist when electric power is used in our homes, offices, factories and near power distribution networks to these locations. 50 Hz fields are created by electric charges which move through conductors of electricity. The frequency of the alternating current of electricity used in Australia is at 50 cycles per second, and so we refer to the electric power as having a frequency of 50 Hz (1 Hz = 1 cycle per second). In Australia, the mains voltage is 240 volts at a frequency of 50 Hz. In North America, the mains voltage is 110 volts at a frequency of 60 Hz.
  24. When electric charges are in motion they produce two kinds of fields: electric fields which result from the magnitude of the electric charge: and magnetic fields which result from the movement of the charges. When an electric toaster is plugged into an electrical outlet, a voltage is applied to the heater wires creating an electric field. As an electric current flows through the wires, a magnetic field is also created.
  25. Electric fields represent the forces that electric charges exert on other charges at some distance from each other, merely because they are charged. For example positive charges are repelled by other positive charges, but are attracted to negative charges. The force producing this attraction or repulsion is due to the electric field.
  26. 26. As charges move (to form an electric current) they create a magnetic field which represents the force that a moving charge exerts on other moving charges. Larger electric currents (more moving charges) produce stronger magnetic fields. For example, the magnetic field produced by a 1000 watt electric heater will be only half as strong as the field produced by a 2000 watt heater. However the electric field from both heaters will be the same.
    Fig02 FIGURE 2 Schematic representation of a 50 Hz field.
  27. The electric currents flowing through the power distribution systems are groups of charges moving in the same direction. All electric currents will produce magnetic fields. Hence all applications using electricity will have associated electric and magnetic fields.
  28. A schematic representation of a 50 Hz field is shown in Figure 2. Figure 3 shows the wavelength as well as the frequency of the electromagnetic wave. 50 Hz fields have a wavelength of 6000 km. Because of this, the electric and magnetic fields of 50 Hz fields act independently. To characterise these fields, it is necessary to measure both the electric and magnetic field strength.

    2.2 Strength of 50 Hz Fields: Natural and Man Made Sources

  29. The electric field strength is measured in units of volts per metre (V/rn) or if the electric field is strong, it may be measured in kilovolts per metre (ky/rn) where 1 kV = 1000 V. 1 ky/rn means there is a differnece of 1 kV between 2 points in air 1 metre apart. If measuring under a HV transmission line the 1 m distance is measured in the vertical direction (between the HV conductors and ground). The magnetic field is measured in terms of lines of force per unit area (magnetic flux density) with units of Tesla (T). Since this is a large unit these fields are commonly measured in millitesla (mT) or microtesla (µT) where 1 Tesla = 1000 mT and 1 mT = 1000 µT. Some people still use the old unit of Gauss (G) where 1 T = 10,000 G or 1 G = 0.1 mT and 10 mG = 1 µT.
  30. To provide some comparison of electric and magnetic field strengths occurring in our working and living environment typical, values for these from common sources are given in Table 1.

    Table 1 - Electric and magnetic fields from devices found in the environment, home and workplace (from: Lee et al 1989, Florig 1987; WHO 1984, 1987)

    Natural fields (at 50 Hz) approx. 0.0000001 approx. 0.000001
    500,000 volt transmission line    
     — directly underneath 7 7–14
     — edge of easement (20 m) 3 2.5–5
     — at 100 m from line 0.1 1–3
    230,000 volt transmission line    
     — directly underneath 2 3.5–7
     — edge of easement (15 m) 1.5 1.5–3
     — at 100 m from line 0.01 0.1–0.3
    Household appliances at 30 cm    
     — Vacuum cleaner 0.02 up to 20
     — Hairdryer 0.04 up to 7
     — Irons 0.06 up to 0.3
     — Toasters 0.04 up to 0.7
     — Electric Shaver   up to 9
     — Television 0.03 up to 2
     — Electric blanket (at user distance) up to 2 up to 5
    Homes (various rooms)   up to 7
    Workplace (distance in m)    
     — Induction heaters (0.1-1)   up to 65000
     — Ladle furnace (0.2-8)   up to 8000
     — Arc furnace (2)   up to 1000
     — VDT's (30 cm)   up to 0.28
  31. As seen in Table 1, many household appliances have associated magnetic fields which are significant when compared to those fields produced by high voltage transmission lines. Electric fields are easily shielded, so those fields associated with appliances are genearlly low compared to transmission lines. Magnetic fields found in homes, as measured by power companies in Australia, have strengths up to about 7 µT (70 mG). Wide variations occur from house to house and from room to room.

    The electric and magnetic fields from high voltage transmission lines fall in strength quite rapidly with distance from the line as shown in Table 1. The fall in electric and magnetic field strength will vary depending on the configuration of the conductors in the transmission line.

    The magnetic fields encountered by workers in certain industries are very large by comparison to those encountered near transmission lines or appliances in homes.

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    2.3 Electromagnetic Fields: Ionizing and Non-Ionizing Radiations

  32. The complete spectrum of electromagnetic radiations and fields is shown in figure 3. This spectrum commences at zero frequency (static field) for both electric and magnetic fields. Above zero frequency and up to 300 Hz the fields are called extremely low frequency fields, where common usage is at power frequencies of 50 to 60 Hz.
  33. Above 300 Hz the fields are designated as radio frequencies (comprising the VLF, VHF and microwave bands). Radiofrequencies include frequencies in the range 300 Hz to 300 GHz (1 GHz = 1,000,000,000 Hz). Contained within the radiofrequency region are microwaves which have frequencies between 300 MHz to 300 GHz (1 MHz = 1,000,000 Hz).
  34. At frequencies above 300 GHz is the infra-red region followed by the visible spectrum (the only part of the electromagnetic spectrum visible to the human eye). Above the visible spectrum is the ultraviolet range.
  35. At the upper end of the ultraviolet range, the energy of the radiation just begins to be strong enough to break molecular and chemical bonds that hold the molecules of cells together. This is the division between ionizing and non-ionizing radiations. Non-ionizing radiations do not have enough energy in the radiation to be able to break these chemical and molecular bonds. However, ionizing radiations are able to break these bonds and cause ion pairs (positive and negative charges-molecules or electrons) within the tissue along the path of the radiation. Ionizing radiations include X-rays, gamma rays and cosmic rays as well as charged particles emitted from radioactive materials.
  36. The energy of radiation within the electromagnetic spectrum is also shown in Figure 3. The 50 Hz fields have extremely low energy and scientists recognise that these fields are unable to produce any form of ionization within tissues. The minimum amount of energy the radiation needs to cause ionization is 12.4 eV. 50 Hz fields have an energy of about i012 eV (one million millionth of the needed energy to produce ions or ionization in tissue). However, 50 Hz fields can interact by inducing currents in the body and in other ways.

    Microwaves on the other hand are absorbed within the tissue causing water molecules to vibrate and generate heat. 50 Hz fields do not generate heat within tissue as to microwaves. However, it has been suggested that if RF fields are modulated (in amplitude) or pulsed at 50 or 60 Hz, these fields can produce an electric field in tissue similar to that produced by a very strong 50/60 Hz field. If RF fields are not modulated, for example they are sinusoidal, their interaction with tissue is not the same strength as 50/60 Hz fields.

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    2.4 How do 50 Hz Fields Interact with the Human Body

    (a) Electric Fields
  37. A human body in a 50 Hz electric field will have a surface charge induced over its surface. This electric charge on the surface of the body will change with the frequency of the alternating 50 Hz field and currents will be induced inside the body. These internal currents have corresponding electric fields, thus both currents and electric fields are induced inside the body by an external 50 Hz electric field.
  38. At 50 Hz the variation in surface charge density is so slow that the currents and fields generated inside the body are very small. As an approximation the electric fields induced inside bodies of humans and animals are about 1 million times less than the field outside the body. The size of the induced currents and fields in the body will be affected by the shape and location of the body relative to the external field.
  39. If a body, while in an electric field, makes contact with a conductor, such as a metal object, then currents will flow from the body into the metal object. While within the electric field, currents can flow through any section of the body. The magnitude of the currents will vary because the body is composed of many different types of tissue which offer varying resistance to current flow.
  40. External electric fields can act directly on the surface of the body and be enhanced (as shown in Figure 4) relative to the unperturbed electric field.
    Fig04 FIGURE 4 - Enhancement of electric fields (concentration of lines of force of the 10 ky/m electric field) by the upper parts of the body of the humans, swine and rats. Note the more highly curved the body, the higher the concentration of electric field, hence the greater induced current over a cross-section of the body (measured as a current density in nanoamperes per square centimetre (nA/cm2) - note 1 nA = 1 billionth of an ampere). The short-circuit current (Isc) is the current passing from the body to ground and is measured in microamperes (µA) where 1A = 1000000 µA. (From Kaune and Phillips, 1980, WHO 1989).
  41. Electric fields can be perceived by the body when hair oscillates in the field. The frequency of this hair vibration is related to the frequency of the applied electric field.
  42. Another well known mechanism of interaction of 50 Hz fields with biological tissues is the direct stimulation of excitable cells such as nerve and muscle cells. This accounts for the ability of humans and animals to perceive electric currents in their bodies and to experience electric shocks. At the cellular level this interaction consists of the induction of voltages across the membranes of cells sufficient to stimulate nerve cells or muscles to contract.
  43. Scientists are currently considering the hypothesis that communication between brain cells occurs not only through nerve cell connections but also through each cells modulation of, and sensitivity to, extra cellular electrical environments. Some cellular studies have been performed on brain tissue and have found that they can be sensitive to induced current densities much smaller than the currents that normally occur within the body. Experiments have shown calcium release from brain tissue immersed in a culture medium and exposed to electric fields in air. These experiments may suggest new mechanisms by which these fields could interact with tissue.


    (b) Magnetic Fields
  44. By contrast to electric fields, the bodies of humans and most other living organisms cause almost no perturbation of the 50 Hz magnetic field to which they are exposed. This is true because almost all human tissue contains no magnetic materials and therefore has magnetic properties almost identical to those of air.
  45. 50 Hz magnetic fields induce electric fields inside bodies just as the external 50Hz electric fields. However, the distribution of these fields induced by electric and magnetic fields is different because of the way they couple to the body (see Figure 5). At the level of the cell however, there would appear to be no fundamental difference between the induced currents and fields from both external electric and magnetic fields (WHO 1989).
  46. Assuming the average tissue conductivity within the body to be about 0.2 S/m (Bernhardt, 1988), one can estimate the magnitude of the currents induced in the body by alternating magnetic fields. 50 Hz magnetic fields of strength up to 500 mT can induce current densities of 1A/m2 on average, which correspond to the minimum value required to stimulate excitable (nerve and muscle) cells. On the other hand, 50 Hz magnetic fields of between 0.5–5 mT are necessary to induce currents of 1–10 mA/m2, which correspond to the range of current densities found normally in the body.
  47. Another effect of 50 Hz magnetic fields is to cause particles of tissue, such as protons (positively charged particles that are influenced by magnetic fields), to experience a force (torque) so that the particles align parallel to the magnetic field. This alignment is resisted by random motion of molecules in tissue due to the fact that the body is warm. So, at normal body temperatures and a magnetic field of the strength which is characteristic under a heavily loaded transmission line, it can be shown that the magnetically induced alignment of particles in living tissue is less than about 1 part in 100 million. The effect of aligning these particles by 50 Hz magnetic fields of any realistic strength, is thus very small. However, some theories suggest that since every single dipole is subject to this effect, it is conceivable that some sort of co-operative physiological processes that are sensitive to the average, response of a great many of these dipoles might be affected by even a small 50 Hz magnetic field.
    Fig05 FIGURE 5 - Currents induced in the body from exposure to electric and magnetic fields—from powerlines for example (from Lee et al, 1989).
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    2.5 Biological Effects From Studies Conducted in Laboratories

  48. Laboratory studies can be divided into two major categories:
    1. In-vitro studies; These are laboratory studies conducted on, for example, cells in culture medium or pieces of tissue.
    2. In-vivo studies; These are laboratory studies carried out on whole organisms such as insects, animals or humans.
  49. There are advantages and disadvantages in conducting both these types of studies. In-vitro studies have the advantage that a large sample size (a large number of single cells) can be studied, as well as a high degree of control maintained over the various factors (eg. temperature, pH, magnetic field exposure) that can affect the experimental results. These studies are also able to provide a direct investigation of possible mechanisms of interaction between biological systems and 50/60 Hz fields with much greater accuracy than an in-vivo system since some of the more subtle effects could be masked in a whole animal for example.
  50. The most serious difficulty with in-vitro experiments is the extrapolation of results to whole animals and humans. Unless the precise mechanisms of interaction are known and well understood, it is not possible to extrapolate results from much less complicated systems such as cells to human beings. Further, effects found from in-vitro experiments will not necessarily occur in animals or humans. In-vivo experiments must be conducted to determine if the same effects occur as in the in-vitro system.
  51. In-vivo experiments allow greater possibility for extrapolation of results obtained in animals to humans. Thus in-vivo experiments are of much greater value for a health risk assessment than in-vitro experiments.
  52. In reviewing the biological effects literature only brief mention will be made of experimental results not related to cancer.
    Comment 3 by Andrew Marino
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    2.6 Initiation & Promotion of Cancer

  53. Tumour development in humans appears to require an initiating exposure to a carcinogen followed by a phase during which there is frequent or continuous contact with a promoting agent and finally, progression to the appearance of a clinically identifiable cancer.
    Comment 4 by Andrew Marino
  54. Low levels of promoting stimuli (below threshold), even under conditions of continual exposure, do not promote the appearance of cancer in initiated cells. Exposure to promoters alone does not cause cancer. Benign or malignant tumours can be caused by exposure to an initiator followed by repetitive exposure to a promoter over a period of time (Boutwell, 1974). However, exposure to a promoter followed by exposure to an initiator does not result in a tumour (Roe, 1959). Changes caused to the cell by promoters are reversible if intervals between exposure to a promoter are sufficiently long (Boutwell, 1964).
    Comment 5 by Andrew Marino
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    2.7 Cell Initiation

  55. What do the laboratory studies suggest regarding damage to the DNA from 50/60 Hz fields that may be related to an initiating event? One of the conventional tests for determining whether a physical or chemical agent is mutagenic is the AMES test. When this test was conducted on prokaryotic cell lines, there was found to be no evidence of mutagenicity from electric fields (Frazier 1982, Williams 1982).
    Comment 6 by Andrew Marino
  56. In-vitro exposure of human lymphoid cells to 50 Hz electric fields that induced current densities up to 0.03 mA/cm2 and/or magnetic fields up to 0.2 mT for 69 hours did not cause chromosome breakage, change the frequency of sister chromatid exchanges or alter mitotic rate or cell cycle duration (Cohen, 1986, Cohen et al 1986 a,b).
  57. Reese et al (1988) exposed chinese hamster ovary (CHO) cells to 60 Hz electric (1 or 38 V/m) or magnetic fields (0.1 or 2 mT) or a combination of both for 1 hour and was unable to detect any single strand breaks in the DNA. Continuous exposure to 60 Hz electric fields that induced current densities up to 3 mA/m2 or a 60 Hz magnetic field of strength 0.22 mT for one or 3 days did not alter the frequency of sister chromatid exchanges or induce micronuclei in human lymphocytes or CHO cells (Livingston et al, 1986). In contrast to this, El Nahas and Oraby (1989) report that when mice were exposed for 24 hours to 50 Hz electric fields at strengths from 100-290 kV/m a dose-dependent increase in micronucleated polychromatic erythrocytes was found up to 4 days post exposure. It should be noted that the electric field strengths used in this set of experiments are very strong indeed. When human peripheral lymphocytes, untreated or treated with chemical mutagens, were exposed to 50 Hz electromagnetic fields, no increase in chromosomal aberrations or sister chromatid exchanges were found (Rosenthal and Obe 1989).
  58. Studies on Drosophila (fruit fly) and animals in general have indicated that exposure to 50/60 Hz fields is not mutagenic (Krueger et al, 1975; Bender, 1976; Frazier et al 1982).
  59. Two strains of mice were exposed to 60 Hz magnetic fields (1 mT) and electric fields (50 kV/m) for up to 22 weeks. No effects were found when tested for dominant lethal mutations or cytogenetic effects (Benz et al 1987). This study is particularly important because of very large numbers of experimental animals (over 2000 mice) were exposed over 3 generations (including juveniles and animals in in-utero) and it was an in-vivo experiment. The results are supported by other experiments and can be considered significant in concluding that 50 Hz fields do not directly damage the genetic material of cells.
  60. Investigators have examined the effect of electric fields on DNA repair processes. Whitson et al (1986) could not demonstrate any effect of electric fields (60 Hz, 100 kV/m) on molecular repair processes after human connective tissue cells were damaged by ultraviolet light.
  61. Conclusion: One can clearly conclude that 50/60 Hz fields do not damage DNA or cause an initiating event in cells.
    Comment 7 by Andrew Marino
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    2.8 Cancer Cell Promotion and Proliferation

  62. If 50/60 Hz fields are not able to damage the genetic material to cause an initiating event in cells, then one looks to studies designed to determine if 50/60 Hz fields can promote cells previously initiated by a physical or chemical agent (other than 50/60 Hz fields). Also, whether exposure to these fields influences proliferation and growth of cancer cells.
  63. Exposure to 60 Hz magnetic fields (strength 1.2 mT) were reported to decrease growth of neuroblastoma in mice (Batkin and Tabrah, 1977). However, no differences in growth characteristics were observed (Chandra and Stefano 1978) when either cultured human bronchiogenic carcinoma cells or Burkitts lymphoma cells were exposed for up to three days to 60 Hz magnetic fields. Kronenberg and Tenforde (1979) reported a similarly negative finding for mouse mammary tumour cells.
  64. Phillips et al (1986 a, b) studied the binding of transferrin to two human colon tumour cell lines, and the ability of cancer cells to form colonies after exposure to 60 Hz electric and magnetic fields (0.03 mA/cm2, 0.2 mT for 24 hours). Altered expression of transferrin receptors and increases in cell colony growth were reported by Phillips and colleagues, but when their results were subjected to a laboratory visit and peer review (Cohen, 1987), it was concluded that their results were invalid because of choice of model, experimental design and quality of data. Further Cohen (1987) was unable to replicate Phillips results. Winters (1986) reported that 60 Hz fields (up to 300 mA/m2 or 0.1 mT for 24 hours) did not significantly affect responses to mitogens.
  65. Female mice at 8 weeks of age were implanted with P388 leukaemia cells and exposed to 1.4 µT, 200 µT or 500 µT, 60 Hz magnetic fields for 3 hours after the implant, for 6 hours daily, 5 days per week until all of the exposed and non treated mice died (Thompson et al 1988). This life-time study found no statistically significant differences in survival, spleen weight or body weight resulting from the P388 cell implant of mice and subsequent exposure or non-exposure to magnetic fields. They also found no effect on the incidence or progression of the P388 leukaemia.
  66. In a comprehensive set of experiments, Frazier et al (1989) (reported only as an abstract) tested the hypothesis that 60 Hz fields could transform initiated (DNA damaged) cells into cancer cells. Using a well accepted cell line (C3H10T112 fibroblasts) for this type of experiment and positive controls, exposure to 60 Hz magnetic fields (up to 0. 6mT) for 6 weeks did not alter transformation frequencies of initiated cells.
  67. What is particularly interesting about the experiments of Frazier et al (1989) is that they used the same classical in-vitro tumour promoting model as Cain et al (1989) (also reported as an abstract), yet Cain et al reported that exposure of C3H10T1/2 cells to a 0.1 mT, 60 Hz magnetic field for 12-16 hours (but not after 2-8 hours exposure) increased ornithine decarboxylase (ODC) activity by up to about 50%. Frazier et al’s results suggest this increased activity may have no effect on transformation of cells into cancer cells. This is also supported by previous studies on cancer promotion involving ODC. ODC is a rate-limiting enzyme in the synthesis of polyamines—molecules essential in supporting growth of cells in all eukaryotic cells and tissues. Increases in ODC activity are associated with healing processes and normal growth. Since cancer promoting agents increase growth rates of initiated cells, one sees increases in ODC during for cancer promotion—however although increases in ODC are essential to cancer promotion, increases in ODC are not by themselves an indicator of a cancer promotion effect (Boutwell 1989).
  68. Recently the question has been examined as to whether the hormone melatonin, produced by the pineal gland, can influence the growth of malignant cells. Breast cancer, melanoma, and possibly other cancers may be inhibited by melatonin (Blask 1989). Since exposure to 60 Hz electric and magnetic fields may reduce the normal nocturnal rise in melatonin (Wilson and Anderson, 1989), Stevens (1989a) suggests exposure to power frequency fields may account in part for an increased human breast cancer risk. To my knowledge none of the epidemiological studies have identified an association between exposure to sinsoidal 50/60 Hz fields and breast cancer.
  69. Conclusion: There is very little evidence to suggest that 50/60 Hz fields have any effect on the promotion stage of carcinogenesis. In fact, key experiments (Thompson et al 1988, Frazier et al 1989) that have been performed suggest strongly that 50/60 Hz fields do not act as a cancer promoter. Overall the laboratory evidence does not establish that there is a link between 50 Hz field exposure and any form of cancer.
    Comment 8 by Andrew Marino
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    2.9 Oncogenes

  70. There are genes in the DNA of the normal human genome which have sequences homologous to (the same as) transforming genes of tumour virus’s (viral oncogenes) and are activated in tumour cells (cellular oncogenes or proto oncogenes). Proto oncogenes have been found in non malignant, normal and uninfected human cells. Somehow the proto oncogenes can be altered and converted into oncogenes during transformation of normal cells into cancer cells (Burck et al, 1988). These cellular oncogenes are called proto oncogenes because they are normal genes with potential oncogenic activity.
  71. Different mechanisms may result in increasing expression of the oncogene or in alteration of the oncogene product, giving rise to deregulation of cellular proliferation. The occurrence of cancer may be determined by the derepression (activation) of endogenous oncogenes. Activation of these repressed genes could result from exposure of cells to chemical carcinogens, radiation, the normal aging process or a combination of these (Huebner and Tobaro, 1969).
  72. Studies have been conducted that show alternating magnetic fields affect gene expression (Goodman and Henderson 1986). These investigators have shown that short exposures to sinusoidal and non-sinusoidal pulsed electromagnetic fields with frequencies in the range 1.5–72 Hz and induced fields of up to 9 mV/m and peak magnetic fields of up to 3.5 mT, increased incorporation of radioactive uridine into RNA, and can alter transcriptional patterns in the X chromosome of Sciara coprophila (fly larvae)—suggesting magnetic fields may stimulate transcription at specific chromosomal regions. Their results (Blank and Goodman 1989) showed that low frequency electromagnetic fields caused the appearance of previously undetected polypeptides (lower molecular weight proteins), some of which were specific to the electromagnetic field signal. These proteins were more highly charged than control proteins.
  73. Conclusion: There has been no research to date which has shown an association between 50/60 Hz fields and gene expression in higher order animals such as humans. The research on fly larvae is only preliminary in nature and needs confirmation and extension to animals before it can serve any value in an assessment of health risk of exposure to 50/60 Hz fields.
    Comment 9 by Andrew Marino
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    2.10 Calcium Ion Transport

  74. Calcium acts as an intracellular messenger and may control many cell functions. A shift in calcium transport across the cell membrane for example, can trigger events such as muscle contraction and hormone secretion. The concentration of biologically active calcium ions must be strictly regulated if normal cell function is to be maintained. Calcium efflux (movement of calcium ions across the cell membrane) usually reflects a change in the status of the cell.
    Comment 10 by Andrew Marino
  75. Movement of calcium ions from freshly isolated chick cerebral tissues exposed to electric fields using a microwave carrier (147 and 450MHz) modulated to ELF (about 16 Hz) frequencies and at multiple power density windows has been reported (Bawin and Adey 1976, Blackman et al 1979, 1982). It should be noted that Bawin and Adey (1976) showed a decrease in calcium efflux while Blackman et al (1979, 1982) showed an increase—a difference which has not been satisfactorily explained.
    Comment 11 by Andrew Marino
  76. Field-induced enhancement of calcium ions from human neuroblastoma cells was observed (Dutta et al, 1984, 1989) using a 915 MHz or 147 MHz carrier modulated at 16 Hz. Field induced calcium release was also observed in vivo, in immobilized cats (cortex) exposed to 450 MHz carrier, 16 Hz modulation at 3 mW/cm2 (Adey et al 1982).
  77. It is suggested that electromagnetic RF fields modulated at 50/60 Hz provide electric fields in situ similar to those imposed by an external sinusoidal 50/60 Hz field. It is claimed that the advantage of using a modulated field is that the RF carrier couples more efficiently with the body than 50/60 Hz fields, and penetrate tissue to provide a higher electric field in situ at the modulation frequency. The RF carrier fields used in the calcium efflux experiments have intensities of about 1.0 mW/cm2, which produces an electric field of approximately 61 V/m in air. Calcium ion efflux occurs within certain frequency modulations and power density windows. These RF fields are associated with tissue gradients of approximately 1–100 V/m in mammalian organisms (Adey 1987). To obtain the same tissue gradient from an external 50/60 Hz electric field, the organism would need to be exposed to a field of strength approximately 1000–10,000 kV/m—some 100–1000 times stronger than fields encountered under power lines.
    Comment 12 by Andrew Marino
  78. RF fields modulated at 16 Hz appear to cause changes to brain tissue in different in vitro preparations. The response to specific frequencies, modulations and different power densities is unusual and some explanation has been provided by Blackman et al (1989). However, the physiological significance of these effects is not established, and certainly the results do not support any suggestion that these exposures constitute a health hazard (Blackman et al 1988).
    Comment 13 by Andrew Marino
  79. What is scientifically unsatisfactory about the results on calcium ion movement is that other laboratories have been unable to provide supporting evidence for the in vitro findings using experimental conditions not exactly the same as the original (Albert et al 1980, 1987). Shelton and Merritt (1981) and Merritt et al (1982), using a different carrier frequency, and experimental conditions, but the same modulation frequency were not able to demonstrate any field-induced enhancement of calcium ions released from rat brain tissue. The term “Cheshire Cat Phenomenon” has been coined to describe the effect because at times the efflux is observed and at other times it is not (Graves, 1986). It is known that the effect is very temperature sensitive and careful control over the experimental conditions must be maintained.
    Comment 14 by Andrew Marino
  80. Gundersen et al (1987) investigated the effect of 60 Hz electric and magnetic fields (30 kV/m or 0.1 mT circularly polarized) on calcium efflux from embryonic chick spinal cord. No significant change in calcium efflux was observed.
    Comment 15 by Andrew Marino
  81. Using strict laboratory conditions in which sample temperature, cell mixing, extracellular pH and ion concentration, and partial gas pressures were carefully controlled, Liburdy and Walleczek (1989) observed no significant alterations in intracellular calcium from resting, quiescent lymphocytes exposed for 1 h to sinusoidal 60 Hz fields (induced currents up to 150 mA/m2, electric field peak 0.1 kV/m, and a magnetic field of up to 22.2 mT rms).
    Comment 16 by Andrew Marino
  82. In one of the few in-vivo studies in this area, Blackwell and Reed (1985) exposed mice to 15, 30 and 50 Hz fields at intensities ranging from 50–400 V/m and examined for behavioral alterations which were associated with calcium flow changes. No such changes were observed.
    Comment 17 by Andrew Marino
  83. Conclusion: Although much work has been conducted on calcium ion movement primarily from in-vitro experiments, there is still great uncertainty whether the effect is an artifact or not, and if it truly occurs, whether it has any significance to health. Further, the fields needed to produce the effect on calcium ions are much greater than would be experienced by people near any power lines. Although only a few in-vivo experiments have been conducted, none have shown any adverse health consequence of calcium ion movement.
    Comment 18 by Andrew Marino
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    2.11 Cancer Promotion Hypotheses

  84. The cancer promotion theory receiving most attention is that proposed by Adey (1986, 1987, 1988). With evidence to suggest that cell membranes are a primary site of interaction of weak frequency or amplitude modulated RF fields (calcium ion efflux), Adey proposes that these fields modulate cell surface chemical events causing an amplification of initial weak triggers associated with binding of hormones, neurotransmitters and antibodies to their sites. Protein molecules traversing the cell membrane form pathways for the signal and energy transfer to the cell interior. Based on evidence from the calcium efflux experiments, it is suggested that fields many orders of magnitude weaker than the cell membrane potential gradient (105 V/cm) modulate cell responses to surface molecules.
  85. Cancer-promoting phorbol esters act at cell membranes to stimulate ornithine decarboxylase (ODC)—a response enhanced by weak radiofrequency modulated (16 Hz) or 60 Hz fields (Byus et al 1987, 1988). In these experiments exposure of cells in-vitro increased the measurable levels of ODC by up to 5 times that of control levels. However, as noted by Boutwell (1989), a true cancer promoter (such as the phorbol ester - tetradecanoyl phorbol acetate or TPA) increases the ODC levels over 100 times. The 5-fold increase found by Byus et al does not suggest a cancer promotion effect. Further, Byus et al indicate the increased ODC activity lasts for about 1–3 hours. Boutwell (1989) states that with true cancer promotors the time frame for ODC induction lasts much longer. According to Bailey (1989), scientists have cautioned about the use of increased ODC activity as a marker of tumour induction, because many physiological stimuli other than tumour promotors are known to affect the ODC activity of cells.
  86. Conclusion: A persisting problem with the calcium promotion theory is that it draws for support on effects produced by RF fields modulated at 16 Hz which have little in common with 50 or 60 Hz sinusoidal fields occurring under power lines. Further, the calcium efflux effect is not consistently observed, suggesting either a very subtle effect or an artifact in the experimental protocol. Finally, the changes in calcium efflux may be within the normal range of variation in animals or humans or may be compensated for in some way so that no change occurs overall. No adverse health consequence of this effect is known.
    Comment 19 by Andrew Marino
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    2.12 Immune Function

  87. Our immune system guards the human body against external agents such as viruses and other antigens. It is the immune system that responds to viral infections to effectively neutralise the effects of the virus and keep the body in good health. Obviously any decrease in immune response could lower resistance to diseases and create a health problem.
  88. To test the effect of 50/60 Hz electric and magnetic fields on immune response, Winters (1986) performed a series of experiments on dog and human white cells. One experiment examined the immune properties of unexposed white blood cells during exposure to 60 Hz fields. Another study was conducted on cells taken from the body after dogs and human volunteers were injected with antigens (a substance that can stimulate immune response). Different combinations of 60 Hz electric and magnetic fields were used in the studies. However, no significant results were found to suggest that 60 Hz fields could affect immune response.
  89. It has been suggested that development of cancer could be enhanced if the immune system of the host was suppressed. Precancerous clones could grow undetected. Evidence that 60 Hz electric fields can suppress T-lymphocyte (cells that participate in the body's immune response) cytotoxicity has been reported by Lyle et al (1988). A 25% inhibition of allogeneic cytotoxicity of the target cell MPC-11 by the murine cytotoxic T-lymphocyte line CTLL-1 was observed when assayed immediately following a 60 Hz field exposed, stimulated spleen cells was not 48 hour pre-exposure of the effector lymphocytes to a 1 kV/m (rms), 60 Hz, sinusoidal electric field. A lower inhibition (19%) was seen using a 0.1 kV/m field. It is suggested that the mechanism of cytotoxicity may have been altered since proliferation was not affected. However, this in-vitro result is not supported by in-vivo results (Morris and Phillips 1982, Morris 1985, Morris et al, 1988).
    Comment 20 by Andrew Marino
  90. Mice were exposed to 60 Hz fields at 100 kV/m for 32 to 150 days. No significant changes in the immune system in terms of primary anti-body response or mitogen stimulation of spleen cells was found (Morris and Phillips 1982, Morris 1985). The reported increase in mitotic index of significantly different to sham exposed mice. This study has recently been extended to rats where no major changes in cell mediated immune responses were observed (Morris et al 1988).
  91. Conclusion: Apart from the study by Lyle et al, studies testing whether 50/60 Hz fields affect the immune system have been negative. It should be noted the Lyle et al study is an in-vitro one and has not been observed in whole animals. One can only conclude from the evidence that exposure to 50/60 Hz fields has little or no effect on the immune system.
    Comment 21 by Andrew Marino
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  92. I believe it would be helpful to outline the criteria used for reviewing scientific literature to remain balanced and objective for assessing health risk. These criteria are used by most national and international organisations. Reference is made to the recently published IRPA/INIRC (1990) guidelines and explanations on development of its rationale for the 50/60 Hz electric and magnetic field exposure limits.
  93. Development of standards that incorporate limits of human exposure to non-ionizing electromagnetic fields has occurred relatively recently. As such, knowledge has been gained from experiences in setting limits for exposure to ionizing radiations—where limits have been lowered on a few occasions as our base of scientific data increased. Standards setters are well aware of the history of events surrounding smoking and asbestos, once considered safe, later to be found carcinogenic.
    Comment 22 by Andrew Marino
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    3.1 Evaluation of Scientific Literature

  94. The development of exposure standards requires an in depth evaluation of the established scientific literature since to base standards on preliminary or unconfirmed data or unproven hypotheses means that the limit values could change significantly with further research. Using established scientific literature allows exposure limits to be determined with a higher degree of confidence about their protective value.
    Comment 23 by Andrew Marino
  95. Certain criteria must be met if claims of positive or negative effects are to be accepted into the body of established scientific literature. These include (WHO 1984, 1987, Repacholi 1989):
    1. Experimental techniques, methods and conditions should be as completely objective as possible.
    2. All data analyses should be fully and completely objective, no relevant data deleted from consideration and uniform analytical methods used.
    3. The published description of the methods should be given in sufficient detail that a critical reader would be convinced that all reasonable precautions have been taken to meet requirements (a) and (b).
    4. Results should demonstrate an effect of the relevant variable at a high level of statistical significance using appropriate tests. The effects of interest should ordinarily be shown by a majority of test organisms and the responses found should be consistent.
    5. Results should be quantifiable and susceptible to confirmation by independent researchers. Preferably, the experiments should be repeated and the data confirmed independently; or the claimed effects should be consistent with results of similar experiments, where the biological systems involved were comparable.
    6. Results should be viewed with respect to previously accepted scientific principles before ascribing them new ones.
    7. For a health risk assessment, greatest value in results conforming to a)–f) above should be placed on reports published in peer reviewed scientific journals. Less weight is placed on data from reports in non-peer reviewed journals, books and abstracts.
    Comment 24 by Andrew Marino
  96. From the body of established literature, a distinction must be made between in-vitro and in-vivo studies. In-vitro studies are conducted to elucidate mechanisms of interaction or to identify biological effects that need to be further investigated to determine if they occur in in-vivo systems. Standards setting organisations can then place in-vitro experiments into context.
    Comment 25 by Andrew Marino
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    3.2 Population

  97. An important part of the rationale for any exposure standard is the definition of the population to be protected. Occupational health standards are aimed at protecting healthy adults exposed as a necessary part of their work, who are aware of the occupational risk and who are likely to be subject to medical surveillance. General population standards must be based on broader considerations, including health status, special sensitivities, possible effects on the course of various diseases, as well as limitations in adaptation to environmental conditions and responses to any kind of stress in old age. As many of these considerations have been insufficiently explored, standards for the general population must involve adequate safety factors, including taking into account the possibility of 24-hr exposure compared with 8-hr occupational exposure (or whatever the duration of the workday).
    Comment 26 by Andrew Marino
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    3.3 Health Hazard

  98. Criteria must be developed to identify which field-induced biological effects are to be considered a hazard to human health. A distinction needs to be made between the concepts of interaction, biological effect, perception, and hazard. Although the quantum energy levels of radiated energy at ELF frequencies are negligibly small, the possibility of an effect from ELF fields cannot be dismissed. Virtually all the energy absorbed by a biological system from 50 Hz field is by inductive and capacitative coupling, and in a few cases by conduction. Thus some interaction must occur, even though it may be a negligible physical perturbation in a dynamic system.
    Comment 27 by Andrew Marino
  99. A biological effect is a physiological perturbation that may or may not be measurable. When a person is merely aware of a physiological perturbation, this conveys the idea of a sensation or perception of the field.
    Comment 28 by Andrew Marino
  100. The difficulty in defining the term health hazard occurs because value judgements are involved that may not be based on scientific analysis. Some people may consider that any field induced interaction is hazardous. Others suggest that the field is hazardous if it is capable of producing a physiological perturbation in a biological system that is either measurable or at least theoretically possible. Still others note that a stimulus producing sensation without pain or discomfort is often assumed to be harmless, but the opposite may be true (Grissett, 1980).
    Comment 29 by Andrew Marino
  101. Czerski and Szmigielski (1975) have noted that in order to understand the effects of exposure to electromagnetic fields, one must have some knowledge of the mechanisms of energy absorption and any direct interference with biophysical and biochemical phenomena in living systems. They suggest that:
    1. all detectable changes in function or structure above the molecular level be termed biological effects,
    2. the immediate effect at the site of primary interaction may induce further changes (secondary or indirect effects),
    3. some time may elapse between the primary interaction and detection of the biological effect,
    4. measurable biological effects that remain within the range of normal compensation are not necessarily hazardous, and
    5. biological effects that may be detrimental to the efficiency of a living system could be hazardous.

    Comment 30 by Andrew Marino
  102. Certainly all of these points must be considered. One could conclude however that interactions which lead to measurable biological effects which remain within the normal range of physiological compensation of the body and do not detract from the physical and mental wellbeing of humans, should not be considered as hazardous. Interactions which lead to biological effects outside the normal range of compensation of the body may be an actual or potential health hazard (Repacholi 1983).
    Comment 31 by Andrew Marino
  103. The fact that a biological change is observed or suspected to occur in humans, does not by itself indicate that the environment which produces the changes is hazardous. A good example is the naïve investigator who sets out to examine the effects of strenuous motor activity. He asked his subject to run for a given period of time. Upon completion of the assigned task, the investigator measured the subject’s blood pressure. After finding a significant elevation in this parameter the investigator searched the literature and was horrified by the ominous import of this findings. The investigator then advised that running is a most dangerous activity (Kahn et al, 1974).
    Comment 32 by Andrew Marino
  104. The second step in standards development is hazard validation. It must be determined whether the reported biological effect produces a truly undesirable state in at least some portion of the exposed individuals. The time course of the effect must be determined, ie under what conditions the effect disappears after rest, or if exposures are additive even after a time out for rest, or whether effects are permanent such as induction of cancer. If it is determined that certain electromagnetic field conditions exist which have a certain probability of being unsafe for some individuals, then the socio-political question must be answered as to what level of safety must be incorporated into the standard.
    Comment 33 by Andrew Marino
  105. The results of epidemiological studies must be carefully evaluated. Epidemiological demonstration of an association between two variables need not imply causality—both may be due to a common factor. However, establishment of causality is enhanced if (Miller 1986, 1989)
    1. the presumed causal event precedes the effect
    2. one rather than multiple diseases (eg. cancers) are caused by a given exposure (specificity of effect)
    3. a dose-response relationship exists or at least the relation between exposure and effect is quantitated
    4. consistency with other observations on cause and effect
    5. the exclusion of concomitant variables (alternative explanations)
    6. disappearance of the effect when the cause is removed, and
    7. the results are consistent with those from animal experimentation and other human observations.
    Comment 34 by Andrew Marino
  106. Not all of these factors can be evaluated or will be true for even the most fully studied effects of exposure to a physical or chemical agent. However, laboratory evidence of this is normally necessary to support the human studies.
    Comment 35 by Andrew Marino
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    3.4 Threshold Exposure

  107. For exposure to any physical agent, there exists a range of biological effects that needs to be assessed for determining health effects. At very high doses clearly adverse physiological effects occur, and a threshold can generally be defined for producing these effects. A consensus of scientific opinion frequently exists which enables us to delineate the range of exposures where no adverse effects occur or appears possible. Controversy sometimes occurs however with regard to the grey area in between these two dose ranges. To develop exposure limits in standards only established biological effects can be considered to determine threshold exposure levels on which the limits are based. Safety factors may be incorporated into the limits depending on the degree of uncertainty about the threshold dose.
    Comment 36 by Andrew Marino
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    3.5 IRPA/INIRC Standards for 50/60 HZ Fields

  108. As an example of using the criteria outlined above, an explanation of the rationale of the IRPA/INIRC (1990) guidelines on exposure limits to 50/60 Hz electric and magnetic fields is given below.
    Comment 37 by Andrew Marino
  109. The IRPA/INIRC (1990) guidelines use as their basic criterion that currents induced by 50/60 Hz electric and magnetic fields should not exceed about 10 mA/m2.
    Comment 38 by Andrew Marino
  110. The 10 mA/m2 criterion was based on the following:

    From an extensive review of the scientific literature, WHO (1987) made the following statement:

    1. Between 1 and 10 mA/m2: minor biological effects have been reported;
    2. Between 10 and 100 mA/m2: there are well established effects, including visual and nervous system effects;
    3. Between 100 and 1000 mA/m2: stimulation of excitable tissue is observed, and there are possible health hazards;
    4. Above 1000 mA/m2: extra systoles and fibrillation can occur (acute health hazards).
    Comment 39 by Andrew Marino
  111. Endogenous current densities in the body are typically up to about 10 mA/m2, although they can be much higher during certain functions. Taking into account more recent data as well, the INIR Committee felt that, to be conservative, current densities induced by external electric or magnetic fields should not significantly exceed this value. Thus, limits for continuous human exposure to electric and magnetic fields were determined using this criterion.
    Comment 40 by Andrew Marino
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    (a) Rationale for Electric Field Exposure Limits
  112. The guideline limits for electric fields were essentially based on the conclusions of WHO (1984) and on more recent reports. In summary form these are:
    1. Animal experimentation indicates that exposure to strong 50/60 Hz electric fields can alter cellular, physiological and behavioural events. Although it is difficult to extrapolate these finding to human beings, these studies serve as a warning that unnecessary exposure to strong electric fields should be avoided.
    2. Adverse human health effects from exposure to 50/60 Hz electric fields at strengths normally encountered in the environment or the workplace have not been established.
    3. The threshold field strength for some human beings to feel spark discharges in electric fields is about 3kV/m and to perceive the field between 2-10 kV/m. There are no scientific data that suggest that perception of a field per se produces a pathological effect.
    4. Although there are limitations in the epidemiological studies that suggest an increased incidence of cancer among children and adults exposed to 50/60 Hz fields, the data cannot be dismissed. Additional study will be required before these data can serve as a basis for risk assessment.

    Comment 41 by Andrew Marino
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    (b) Experimental studies
  113. A large body of data has been collected on blood chemistry changes in animals exposed under different conditions; no consistent picture of physiological changes is evident.
    Comment 42 by Andrew Marino
  114. Results of behavioural experiments on animals which suggested an effect of exposure, were at levels at or above those needed for sensory perception of the field. Most behavioural tests showed no effects with exposure to electric field strengths up to 10 kV/m (WHO 1984, Ahlbom et al 1987). Effects on behaviour have been reported only in isolated instances from electric field exposure inducing current densities as low as 3 mA/m2. Health consequences, if any, of these observations require further studies.
    Comment 43 by Andrew Marino
  115. Many studies on laboratory animals (rodents) have indicated that there are no significant adverse effects on growth and development. Multi-generation studies in swine and rats exposed to electric fields (30 kV/m and 65 kV/m respectively) revealed developmental defects (Phillips 1983). These results were not confirmed in recent, well controlled studies on rats (Rommereim et al 1988, Sikov et al 1987).
    Comment 44 by Andrew Marino
  116. Evaluation of the evidence from many studies indicates that animal morbidity and mortality are unaffected by long-term exposure. Such studies were carried out on small laboratory animals (rats and mice) at unperturbed 50/60 Hz electric field strengths up to 100 kV/m (Bonnell et al 1986), and on larger animals, including miniature pigs, at levels near 30 kV/m (Phillips 1983).
    Comment 45 by Andrew Marino
  117. Conclusion: At this point in the rationale for the electric field limits, one concludes that the laboratory studies have not clearly identified any pathology that can be attributed to exposure to the 50/60 Hz electric field per se. Any effects seem to result predominantly from sensory perception—not normally considered as an effect leading to a health hazard.
    Comment 46 by Andrew Marino
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    (c) Human studies
  118. At 50/60 Hz a field strength of 20 kV/m is the perception threshold of 50% of people for sensation from their head hair or tingling between body and clothes; as shown under laboratory conditions a small percentage of people can perceive a field strength of 2 or 3 kV/m (Cabanes and Gary 1981, IEEE 1978).
  119. Controlled laboratory studies on human volunteers exposed for short periods (a few hours) to electric field strengths of up to 20 kV/m have, in general, shown no significant effects (WHO, 1984). However, these data do not establish that health effects could not occur from long-term exposure (months or years).
    Comment 47 by Andrew Marino
  120. Well-controlled studies on the health status of linemen and switchyard workers have not revealed any statistically significant differences between exposed and control groups (Knave et al 1979, Stopps and Janischewsky 1979, Baroncelli et al 1986). These studies are among the more complete and are representative of high levels of occupational exposure. Because of the small populations studied and the resulting low statistical power, these studies cannot exclude the existence of small effects in these highly exposed populations.
    Comment 48 by Andrew Marino
  121. Several studies of the incidence of cancer or mortality from cancer among arbitrarily defined occupational groups considered to be exposed to electromagnetic fields (among other factors) suggested an association between “electrical occupations” and cancer. Because of the inherent uncertainty associated with this type of epidemiological study, and the lack of measurement of exposure, no definitive conclusion can be drawn (WHO,1984, 1987, 1989; Repacholi, 1988).
    Comment 49 by Andrew Marino
  122. Recent epidemiological studies (Savitz, 1988) provided some support for the findings of a previous study on childhood cancer and exposure to weak 50/60 Hz fields (Wertheimer and Leeper 1979). Both studies were carried out in the same geographical area and on a similar population, thus the conclusions drawn from both reports cannot be generalized. A scientific panel (Ahlbom et al 1987) which evaluated the implications of these epidemiological studies concluded that the association between cancer incidence and 60 Hz field exposure is still not established and remains a hypothesis. The INIR Committee concurs with this conclusion. To date, chronic low-level exposure to 50/60 Hz fields has not been established to increase the risk of cancer (WHO 1987, 1989).
    Comment 50 by Andrew Marino
  123. From the experimental data and human studies it was concluded (WHO 1984) that no adverse health effects resulted from short-term exposures at strengths up to 20 kV/m at frequencies of 50 and 60 Hz.
  124. Conclusion: For standards development, the short-term exposure results identified in the human volunteer studies are useful only to the extent that they establish that acute exposure to high field strengths is not detrimental. This suggests that brief exposures by workers to higher fields than may finally be determined for continuous exposure should not cause any adverse health effect. However, studies performed on high voltage transmission line and switchyard workers are more useful for identifying long-term health effects. Unfortunately, because of low numbers of workers studied, these studies could only identify possible gross effects. Fortunately however, these workers are in the group of highest possible electric field exposures. If one assumes that higher voltage exposure should be more detrimental, then the results of these studies, even though they have a low statistical power, provide a measure of confidence that exposure to low field strengths should not be adverse to health. Finally, the studies on occupational and general populations tend to suggest that electric field exposure is not related to an increased cancer incidence. From the above, one can conclude that electric field exposure, even at high levels, does not produce an adverse health outcome.
    Comment 51 by Andrew Marino
  125. Steady-state 50/60 Hz current from contact with charged objects can produce biological effects that range from just noticeable perception to ventricular fibrillation and death (WHO 1984). The severity of an electric shock from touching a charged object depends upon a number of factors including grounding conditions, the magnitude of contact current, the duration of current flow, and body mass.
    Comment 52 by Andrew Marino
  126. Currents above the 10 mA level represent a serious risk, because the “let-go” threshold (current intensity above which a person cannot let go of a gripped conductor as long as the stimulus persists due to uncontrollable muscle contraction) may be exceeded, and the individual might not be able to release a charged object due to involuntary muscle contractions (IEEE 1978, IEEE 1984). The estimated level of let-go current in small children is approximately one half of that for an adult man. If the current is increased beyond the let-go value, there is a possibility that ventricular fibrillation can occur. Short circuit current resulting from touching charged objects can be related to unperturbed field strengths (Guy 1985).
  127. Typical threshold values resulting from steady-state contact currents of 50/60 Hz from insulated vehicles (IEEE 1978), Zaffanella and Deno 1978, UNEP/WHO/IRPA 1984) include:
    • 10–12 kV/m: Median pain perception for children, finger contact, car;
    • 8–10 kV/m: Painful shock for children, finger contact, truck;
    • 4–5 kV/m: Median touch perception for men, finger contact, car;
    • 2–2.5 kV/m: Median touch perception for children, finger contact, car.
  128. Transient capacitative discharges can occur between a person and a charged object via a spark through an air gap. The human reaction to transient electric shocks from spark discharges has been shown to depend in a complex manner on the discharge voltage and the capacitance of the discharging object (IEEE 1978). The sensitivity of individuals to transient discharges has a linear dependence on body mass (Larkin et al 1986). Other factors such as sex, age or skin hardness have no correlation with the threshold sensitivity of an individual to transient electric discharges. Data obtained on adults exposed to spark discharges of various intensities showed that 50% of the subjects perceived spark discharges in a field of 2.7 kV/m and 50% found the spark discharges annoying at 7 kV/m (Zaffanella and Deno 1978). To obtain these data, persons standing in an electric field touched a metallic post with a finger; it is assumed that their capacitance was of the order of 170 pF.
  129. Conclusion: It has been recognised for a long time that perception and shocks occur from charged objects in electric fields. Quantitating this effect is necessary since it has an impact on limits of exposure for the general public. The INIR Committee felt it unreasonable to set exposure limits for the public at a level where they must avoid transient discharges. If perception of the field is not considered a health hazard but spark discharges are, then, from the above, consideration needs to be given to setting a limit of continuous exposure to electric fields between 2.7–7 kV/m. The INIRC chose a limit of 5 kV/m as the limit for general public exposure.
    Comment 53 by Andrew Marino
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    (d) Derivation of exposure limits
  130. INIRC proposed a criterion that the external electric and magnetic fields induce a current density of no greater than lO mA/m2 in the body since this is within the range of endogenous current densities. Knowledge about the possible effects of long term exposures to fields inducing currents near the criterion value is still limited and most evidence is based on short term observations.
  131. In view of these reservations the continuous occupational exposure should be limited to 10 kV/m, inducing a current density of 4 mA/m2 on average. There is substantial workplace experience in addition to controlled laboratory studies on volunteers which indicate that short-term exposures to fields up to 30 kV/m have no significant adverse health consequences. Exposures to electric fields between 10 and 30 kV/m produce proportionally increasing discomfort and should be limited in duration accordingly. The INIRC suggests a practical approach to limiting the duration of exposure to fields between 10 and 30 kV/m is to use the formula t < 80/E over the whole working day, where t is the duration of exposure in hours to a field strength of E kV/m.
  132. For the reasons given above (populations), a further safety factor was incorporated for exposure of the general public. A safety factor of 5 with respect to the criterion of 10 mA/m2 was introduced leading to a limit of 2 mA/m2 which corresponds to an electric field strength of 5 kV/m.
  133. The limit of 5 kV/m for continuous exposure of the general public also provides substantial protection from annoyance caused by steady state contact currents or transient discharges. This limit, however, cannot completely eliminate perception of the electric field effects, since the perception threshold for some people is below 5 kV/m. In such cases additional technical measures (eg grounding) may be instituted to avoid indirect coupling effects arising from touching charged, ungrounded objects. It should be noted that continuous exposures outdoors of the general public rarely exceed 1–2 kV/m (Tenforde and Kaune 1987).
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    (e) Rationale for Limits on Magnetic Field Exposures
  134. In terms of a health risk assessment, it is difficult to correlate precisely the internal tissue current densities with the external magnetic flux density. However, assuming a 10 cm radius loop in tissue of conductivity 0.2 S/m, it is possible to calculate the magnetic flux density that would produce potentially hazardous current densities in tissues. The following statements can be made for induced current density ranges and magnetic flux densities of sinusoidal fields that produce biological effects from whole-body exposure (WHO 1987):
    1. Between 1 and 10 mA/m2 (induced by magnetic flux densities above 0.5 and up to 5 mT at 50/60 Hz), minor biological effects have been reported. Note: this is in the range of current densities normally occurring in the body.
    2. Between 10 and 100 mA/m2 (above 5 and up to 50 mT at 50/60 Hz) there are well established effects, including visual and nervous system effects.
    3. Between 100 and 1000 mA/m2 (above 50 and up to 500 mT at 50/60 Hz) stimulation of excitable tissue (nerve cells and muscle tissue) is observed and there are possible health hazards.
    4. Above 1000 mA/m2 (greater than 500 mT at 50/60 Hz) extra systoles and ventricular fibrillation can occur (acute health hazards).
  135. Several laboratory studies have been conducted on human subjects exposed to sinusoidally time-varying magnetic fields with frequencies of 50/60 Hz. None of these investigations has revealed adverse clinical or physiological changes. The strongest magnetic flux density used in these studies with human volunteers was a 5 mT, 50 Hz field to which subjects were exposed for 4 hours.
  136. The above data are mutually supportive. From an analysis of various data, effects can be based on ranges of induced current densities. At the higher end of the lowest range (10 mA/m2) is the upper value of endogeneous current density—this approximates to a current density induced by an external 50/60 Hz magnetic field of 5 mT. Short-term human exposure to this field strength has not been shown to be detrimental. Thus acute exposure limits could be based on inducing current densities no more than 10 mA/m2. To account for possible effects from long-term exposure, safety factors need to be incorporated into the continuous exposure limits.
  137. Some epidemiological reports present data indicative of an increase in the incidence of cancer among children, adults, and occupational groups. The studies suggest an association with exposure to weak 50 or 60 Hz magnetic fields. These associations cannot be satisfactorily explained by the available theoretical basis for the interaction of 50/60 Hz electromagnetic fields with living systems. The magnetic flux densities in some epidemiological studies suggesting an increased cancer incidence are at values near 0.25 µT. This magnetic flux density would induce a current density that is well below those levels normally occurring in the body. The epidemiological studies are not conclusive. Although these epidemiological data cannot be dismissed, there must be additional studies before they can serve as a basis for health hazard assessment. Furthermore, scant laboratory evidence is available to support the hypothesis that there is an association between 50/60 Hz fields and increased cancer risk.
  138. The total number of direct observations of the effect of magnetic flux densities in humans is limited. Controlled laboratory studies on human volunteers exposed for 4 to 6 hours per day for several days to magnetic flux densities up to 5 mT (together with electric fields up to 20 kV/m) did not demonstrate significant effects (WHO 1987, Sander et al 1982). Therefore the short term occupational exposure should not exceed 5 mT (inducing current densities of 10 mA/m2, the criterion value) and 25 mT for the extremities. The extremity value takes into account the loop diameters in the limb which are about 1/5 of those in the trunk.
  139. Because of the sparseness of data on long term exposures to magnetic fields the magnetic flux density for continuous exposure in the occupational environment should incorporate a safety factor of 10, and so is limited to 0.5 mT.
  140. For reasons developed above, under the heading “Populations,” the limit for continuous exposure of the general public was set at 0.1 mT, a factor of 5 below the limit for continuous occupational exposure, while the short term exposure limit was set at 1 mT.
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    3.6 Standards - National and International

    (a) International
  141. The International Non-Ionizing Radiation Committee (INIRC) of the International Radiation Protection Association (IRPA) has completed a thorough objective analysis of current knowledge and drafted interim guidelines on human exposure to 50/60Hz fields. Key to the issuance of their guidelines (IRPA/INIRC, 1990) was the determination that the scientific evidence does not suggest that current levels of exposure present a hazard to health. The interim guideline is given in Table 2.


    Table 2: Limits of exposure to 50/60 Hz electric and magnetic fields (IRPA/INIRC, 1990)
    Exposure Characteristics Electric Field Strength (kV/m) (rms) Magnetic Flux Density (mT) (rms)
    Whole working day 10 0.5
    Short term 30(a) 5(b)
    For limbs 25
    Up to 24 hours per day(c) 5 0.1
    Few hours per day(d) 10 1


    (a) The duration of exposure to fields between 10 and 30 kV/m may be calculated from the formula t< 80/E where t is the duration in hours per workday and E is the electric field strength in kV/m;

    (b) Maximum exposure duration is 2 hours per work day;

    (c) This restriction applies to open spaces in which members of the general public might reasonably be expected to spend a substantial part of the day such as recreation areas meeting grounds and the like;

    (d) These values can be exceeded for a few minutes per day provided precautions are taken to prevent indirect coupling effects.

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    (b) Australia
  142. The National Health and Medical Research Council (NH&MRC) has accepted in total the IRPA/INIRC (1990) guideline as the health standard for Australia. The NH&MRC approved the international standard at its November 1989 meeting and they will have available the final publication in 1990.
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    (c) United Kinqdom
  143. The National Radiological Protection Board (NRPB), the radiation protection authority and radiation research council for the United Kingdom, recently completed a thorough review of the literature on electromagnetic fields and published a set of human exposure guidelines (NRPB 1989). For the 50/60 Hz fields, the NRPB based its guidelines on limiting induced currents in the human body—exactly the same basis as the IRPA/INIRC (1990). The NRPB sets a basic restriction on continuous induced current in any arm, hand, leg, ankle or foot of 1.03 mA for a frequency of 50 Hz.
    (d) Federal Republic of Germany
  144. The committee developing the Deutsche Norme for the FRG have produce a draft setting limits of 50 Hz field strengths. This draft is to come up for final approval in the summer of 1990 (Bernhardt 1990—personal communication). For 50 Hz the FRG (1990) draft recommends:
      electric field (kV/m) magnetic field (mT)
    upper limits 31 7.5
    continuous limits 20 6.5
  145. The draft limits are applicable to both workers and the general public, although Bernhardt (1990) claims a two-tier proposal is being formulated to provide lower limits for general public exposure. The standard is based on limiting currents induced in the body—as with the IRPA and NRPB standards.

    (e) USSR
  146. The Soviet Union currently has a standard for occupational exposure to 50 Hz magnetic fields (USSR 1985) issued by the Ministry of Public Health. The standard limits exposure to continous wave 50 Hz fields to 7.5 mT for 1 hour and 1.8 mT for 8 hour exposures per day. Details of the standard are provided in WHO (1987).
  147. For 50 Hz electric fields, the Soviet Union allows unrestricted exposure to 5 kV/m (USSR 1975). Time restrictions are placed on exposure to higher field strengths. The standard is explained in WHO (1984).
  148. Table 3 gives the international and national exposure limits for comparison with the typical exposure levels at the nearest dwelling to the proposed Mt Piper to Marulan 500 kV Transmission Line.
    Table 3: Limits of exposure to 50/60 Hz fields permitted by the national and international standards compared to dwellings along proposed Mt Piper to Marulan Transmission Line.
    Country/Case Electric Field (kV/m) Magnetic Field (µT)
    (occupational) 10 500
    30 (2 h/day) 5000 (2 h/day)
    (general public) 5 100
    100 (few h/day) 1000 (few h/day)
    (occupational) 10 500
    30 (2 h/day) 5000 (2 h/day)
    (general public) 5 100
    10 (few h/day) 1000 (few h/day)
    Federal Republic of Germany
    (occupational and general public) 20.6 5000
    United Kingdom
    (occupational and general public) 12 2000
    occupational 5 1800
    10 (3 h/day) 7500 (1 h/day)
    Typical exposure at closest dwelling 0.012 0.17

    Comment 54 by Andrew Marino
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    4.1 Terms of Reference

  149. I have been asked to examine:
    1. the contents of the EIS with a view to assessing, from my area of expertise, the adequacy of the presentation of the EMF issue and the conclusions drawn in the EIS,
    2. some of the information provided to the determining authority (which I understand was the Board) subsequent to the publication of the EIS and before making their decision in February, 1988. Again with a view to assessing from my area of expertise the adequacy of analysis and conclusions in that information, and
    3. whether the conclusions expressed in the EIS and before the Board are still valid to date, in light of any recent research results.
  150. I understand that the Oberon Powerline Investigation Committee, the Applicant in these proceedings, challenges:
    1. (a) the content of the environmental impact statement; and
    2. (b) the decision to proceed with the line, as embodied in the Clause 64 Report.

    4.2 Response to Terms of Reference

    (a) Environmental Impact Statement: Preliminary Comments
  151. In my review of the EIS, my opinions are based on my knowledge of the subject, and, in particular, detailed reviews of the WHO (1982, 1984, 1987, 1989) and IRPA (1990) documents.
  152. I have read appropriate sections of the environmental impact statement (EIS), these being sections 8.6.1–8.6.5 and have the following comments.
  153. After an appropriate introduction to what electric and magnetic fields are in terms of power transmission, section 8.6.1 identifies the most serious hazard of these lines, that being electrocution. This hazard is well known and has been adequately identified in this statement. Section 8.6.2 describes the magnetic fields surrounding the high voltage transmission lines and compares them with both the ambient and man-made fields. This type of information is appropriate for documents such as this.
  154. Humans perceive fields from around 2-3 kV/m in laboratory situations where other factors are eliminated. However, in the normal environment, most people would not be able to perceive fields much lower than 10 kV/m.
  155. The EIS draws largely on the text of the World Health Organisation/International Radiation Protection Association document published in 1984. This document, entitled “Environmental Health Criteria 35—Extremely Low Frequency (ELF) Fields,” was specifically designed to summarise the bioeffects literature on effects of electric field exposure, identify gaps in knowledge from the research conducted to date and to provide recommendations and conclusions from current knowledge. This document was followed by an environmental health criteria on 50/60 Hz magnetic fields, published in 1987, after the EIS was published.
  156. In quoting from two detailed reviews of the scientific literature pertaining to biological effects and adverse health effects of exposure to 50/60 Hz fields, the EIS is in my opinion, comprehensive in its treatment of the subject, as the reviews were authoritative and the EIS faithfully related their conclusions.
  157. Since the EIS was published in February 1987, it does not quote the report by Savitz (1988). This study, conducted under the New York Power Lines Project was undertaken to determine if the conclusions of the Wertheimer and Leeper (1979) study could be reproduced. The conclusions of the Savitz study appeared as an unpublished report in 1986 and were presented in published form to the New York Power Line Authority in 1987. It was finally published in the scientific literature in 1988. It would not be reasonable to expect people who were not closely involved with research in this area to have known of the early Savitz report and its possible implications in setting off a debate as to whether exposure to 50/60 Hz fields is associated with cancer.
  158. In section 8.6.4, on public health implications of electric and magnetic fields, the EIS relies almost exclusively on the World Health Organisation (1984) and Graves (1986) documents. Most of the appropriate conclusions of these two studies are quoted verbatim in the EIS.
  159. It is also noted that the Chairman of the Radiation Health Committee of the National Health and Medical Research Council was contacted to determine if the 1984 WHO document was considered to be authoritative of the subject. The Chairman concluded that the recommendations of the WHO offered an acceptable basis for the design and operation of high voltage transmission lines. This information was received in August, 1985. As a member of the Radiation Health Committee, I remember this being discussed and can concur with the statement made in the EIS.
  160. In addition to the above preliminary comments I have the following specific comments relating to the EIS. Noting that the document was published in February, 1987, its preparation would likely have been at the end of 1986, so my comments will be with this understanding.
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    (b) Comprehensiveness
  161. The EIS is comprehensive enough to direct a reasonably intelligent, informed mind to possible or potential environmental consequences of carrying out or not carrying out an activity.
  162. As noted above, the purpose of the WHO documents is to provide a comprehensive, objective, unbiassed review of the scientific literature. It is intended to be authoritative and provide a document that decision makers can rely on. Noting that the WHO (1984) document dealt predominantly with electric fields and that the Graves report had been accepted as authoritative by the Victorian Government, the authors of the EIS completed their literature review with authoritative documents for both electric and magnetic fields. If decision makers do rely on the content of the documents and extract conclusions faithfully so that reasonably intelligent minds are alerted to any adverse health consequences of the power line, then in my opinion the EIS would appear comprehensive in its treatment of the subject matter.

    (c) Objectivity
  163. I have read the EIS and have noted that all the quotations contained therein are accurate reproductions of those in the WHO and Graves reports. I believe that the relevant conclusions of these two documents are contained in the EIS. It was reasonable for the writers of the EIS to rely on the WHO document since the text of that report was developed by an international group of experts brought together to review all of the scientific literature and reach consensus conclusions.
  164. Given the reputation of WHO in the health field, its recommendations are generally accepted without question and are considered as authoritative as can be obtained. However, the authors of the EIS took the further step of asking the Federal Health Departments expert committee on radiation protection (Radiation Health Committee) to advise whether the WHO document was authoritative and appropriate to high voltage power lines being constructed.
  165. The accuracy of the WHO report or its conclusions are not in question since the appropriate Federal authority validated it to the authors of the EIS.
  166. The authors of the EIS also accepted the conclusions of the Graves report which had been commissioned by the Victorian Minister for Health and had been accepted by the Victorian Government as reaching appropriate conclusions for the power line that was under consideration in Melbourne between Richmond and Brunswick. The density of population along this power line was vastly greater than the Mt Piper to Marulan Line. I believe the authors could not be faulted for this.
  167. Objectivity comes from following appropriate criteria for the selection of scientific literature as outlined above. This literature is then weighed on the basis of these criteria. WHO has followed this objective selection process, and since the EIS follows the WHO, in my opinion it was properly objective. The EIS would not be as objective if the authors (non scientists) attempted to review the scientific literature without making the objective selection conducted by WHO.
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    (d) Alerting lay persons and specialists to relevant problems or issues.
  168. Within the EIS pages 174–178 there is general reference to health effects and particularly cancer. Although, as a scientist, I could compile a complete listing of biological effects which may relate to possible health effects of exposure to electric and magnetic fields, I believe cancer is the one that would alert people to the highest level. If people are alerted to what is generally regarded as the worst possible health effect yet that is not later found to be related to exposure to electric and magnetic fields, the EIS, in my opinion, has raised peoples’ attention to possible health effects.

    In the EIS page 178, it is stated that:

    “At the same time, however it is acknowledged that there is a small group of scientists who are concerned about such fields, but who do not currently have any compelling or consistently repeatable evidence of a health effect. This group believes that some studies indicate a potential cancer risk and that future work may demonstrate an actual risk. The marginal increases in cancer reported in these studies are of the order that could happen occasionally and unexpectedly in any study. They would normally attract no attention unless they were found to be consistently increased in a number of studies—something that has not happened.”

    This statement was in my opinion, a true reflection of the field in February, 1987. Not only does this paragraph alert people to the fact that there was a group of scientists still concerned that 50 Hz fields could be associated with an increased cancer incidence but the paragraph does conclude with the state of knowledge on these studies, as reflected by the WHO and Graves reports.

    As stated previously, the WHO reports are compiled to be authoritative, fair and objective views of the scientific literature. In that the EIS reflects the conclusion the WHO report, it can also be seen as fair and objective. The statements made about exposure to electric and magnetic fields and cancer are reasonable and correct as they are today.

    (e) Identification and analysis of likely environmental interactions
  169. I have assumed that “environment” is taken to be the surroundings of man, but not man himself. However, the claimed effects on man have been addressed above.
  170. The EIS goes to some length to summarise the conclusions of most studies that have been conducted on farm animals and plants exposured to 50/60 Hz fields. To my knowledge, the scientific literature on this subject has been quoted and summarised correctly. One might criticize the EIS for not having made a similar effort with respect to biological effects that could be related to adverse health effects. However, when one notes that the literature on this subject is vast, it is not unreasonable for the authors of the EIS to refer to authoritative summaries of this literature such as the WHO and Graves reports. Further, as the Mt Piper to Marulan line would go through predominantly rural areas, it could be argued that, since the nearest residence is 180 m from the line, and the WHO and Graves reports state no adverse health effects are expected, most people may be more interested in possible effects on livestock and crops or on clearing vegetation and its effect on endangered species than health effects to themselves.
    (f) Identification and analysis of likely environmental impacts.
  171. Having identified much of the literature on 50/60 Hz exposure of animals and plants in their living environment, the EIS correctly concludes that, from the many years of research that have been conducted, typical exposure to fields associated with the transmission line would not produce any adverse effect on live stock or plant life. In my opinion, I believe the authors have reasonably identified and analysed the likely environmental impact and interactions of the proposed power line and have reached reasonable conclusions based on the evidence available to them.

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    (g) Conclusions of WHO and Graves’ reports in EIS

    (i) Conclusion drawn from the WHO criteria No 35. “Adverse human health effects from exposure to ELF electric field levels normally encountered in the environment or the workplace have not been established”

  172. I agree with this conclusion. This conclusion has been reconfirmed in the recent WHO (1989) report as well as the IRPA (1990) interim exposure limits on 50/60 Hz fields. From my own knowledge of the literature and my recent review (Repacholi, 1990), I conclude that there has not been established any adverse health effect of exposure to ELF fields encountered in the environment.

    (ii) quotations from the WHO report on paqe 177 of the EIS.

  173. I chaired the WHO Committee that finalised WHO (1984) and am very familiar with its conclusions. I can state categorically that these conclusions reasonably and fairly represent the conclusions of the WHO report as they apply to human health consequences of exposure to electric fields. The other conclusions of the WHO report not mentioned in the EIS are worker-safety related or recommendations for further research in areas where gaps in knowledge were identified and would not be relevant to the EIS.

    (iii) conclusions of Dr Graves’ report stated below:

    “It is not possible to make unequivocal statements about the potential health hazards of any agent. However, a careful review of the literature on biological, including human health, effects of extremely low frequency electric and magnetic fields leads to the firm conclusion that no adverse health effects of exposure to fields in the range of those associated with SECV transmission lines or stations have yet been established and to the further conclusion that such adverse health effects are very unlikely. It is therefore concluded that SECV practices regarding electric field strength on transmission line easements or in stations are not considered to pose a public health problem. This conclusion is consistent with conclusions of essentially all major reviews on biological effects of electric and magnetic fields.”

  174. I agree with the conclusions of Dr Graves’ report because they are substantially similar to those of the WHO 1984 and 1987 reports and all major reviews of biological effects of electric and magnetic fields that were conducted at that time (1986). It must be remembered that the Graves report had been accepted by the Victorian Government and so the authors could correctly assume the document was authoritative, fair and objective, as well as being applicable to the proposed Mt. Piper to Marulan line since the population near the line was much lower than the line in Victoria to which the Graves report referred.
  175. I believe that the paragraphs quoted in the EIS (page 178) accurately reflect the overall conclusions of the Graves report on health effects from exposure to 50/60 Hz fields, and that the conclusions of the Graves report are accurately reflected by the EIS. It should be noted that Dr Graves makes the comment that it is not possible to make unequivocal statements about the potential health effects of any agent. This is true in any aspect of science since one cannot prove a negative. However, scientists reach appropriate experiments inferred in Dr Graves’ statement and in my view, is entirely correct, fair and objective.

    (h) Statements in the EIS
  176. On page 178, the EIS states:

    “At the same time, however, it is acknowledged that there is a small group of scientists who are concerned about such fields, but who do not currently have any compelling or consistently repeatable evidence of a health effect. This group believes that some studies indicate a potential cancer risk and that future work may demonstrate an actual risk. The marginal increases in cancer reported in these studies are of the order that could happen occasionally and unexpectedly in any study. They would normally attract no attention unless they were found to be consistently increased in a number of studies—something that has not happened.”

    “It may be concluded, on the bulk of scientific evidence, that the electric and magnetic fields associated with the proposed transmission line would not pose a threat to public health.”

  177. The first of these paragraphs alerts the reader to the fact that there is a conflict of opinion amongst scientists and accurately summarises their major concerns about possible adverse health effects. The authors of the EIS conclude that the small increases in cancer incidence reported in the studies are of the order that could happen occasionally or unexpectedly in any study. That is to say that these positive reports could occur by chance alone. In late 1986 early 1987, this was the opinion of most scientists given that the degree of exposure of people to the magnetic fields could not be accurately determined. Others felt the results were probably due to confounding factors not accounted for in the studies.

  178. Since early 1987, there have been many more studies published which have produced equally conflicting and controversial results. The conclusion noted in the second paragraph in section 38 is effectively the conclusion of the two authoritative reports of WHO and Dr Graves. Further, since the nearest residence would be 180 m from the proposed transmission line and the typical exposures to people in this dwelling would be well below the 2.5 mG threshold suggested by the Savitz study, even the epidemiological studies reporting a positive association with cancer would not suggest these residents are at an increased risk of contracting cancer.
  179. Although I believe the WHO and Graves reports are accurate, even if one assumes the contents are not valid, the authors of the EIS were given to understand that these documents were authorative reviews of the literature by the Federal Government’s Radiation Health Committee (the Federal Governments expert committee on radiation protection). Thus, in my opinion, they could reasonably assume that the conclusions reached by the two reports were applicable and accurate. The WHO reports are written with the purpose of being relied upon and appropriate actions taken that depend on these reports.

    (i) Analysis of possible effects on farming activities
  180. As stated the scientific literature on this area is not nearly as extensive as the body of literature conducted to determine if adverse human health effects exist. However, much of the literature relating to experiments on laboratory animals would also be pertinent to farm animals and so the conclusions would be similar.
  181. The literature in the EIS on farming activities refers to animals and plants investigated within their normal environment except that they are exposed to electric and magnetic fields from the power lines. From my knowledge of this literature the EIS has summarised accurately most of the studies that have been conducted. Many of the reports quoted gave results of studies conducted using electric and magnetic fields much greater than those expected from the 500 kV line. These studies were conducted under 765 and 1100 kV lines. I have had cause to review these reports previously and the conclusions reached are accurate and essentially in line with all of the other biological effects literature on animal experimentation in laboratories.
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    4.3 Board Papers

  182. I understand that before the Board made its decision in February 1988, it had had before it Board papers dated 22 September, 1987 and 6 November, 1987, together with a draft documents which was relevantly identical to the Clause 64 report. From the Board papers one notes the Board requested information on 50/60 Hz fields independently of the EIS process. It can also be seen from the draft Clause 64 report which summarises the objections raised by members of the general public that the public were definitely alerted by the EIS to possible health effects from the proposed power lines. The Board was also alerted to the fact that considerable effort was being conducted by researchers to determine if there were truly any adverse health effects from exposure to these fields.
  183. From my review of the papers, the Electricity Commission appeared to be making every effort to stay informed with the latest developments on research and standards. It was informed of the impending publication of the WHO Environmental Health Criteria 69 on magnetic fields and was alerted to the draft exposure standard that was being prepared by the International Radiation Protection Association. It knew there was a Scientific Advisory Panel overseeing the New York State Power Lines (NYSPL) project.
  184. The Boards attention was drawn to one of the major studies of the NYSPL project, that being from Dr Savitz who suggested that an increased risk of childhood cancer may be associated with certain types of electric wiring in residential streets. The Board was also informed that similar studies had been conducted which did not find any such relationship.
  185. I believe that the Board papers show that information provided to the Board by the Commission’s officers was fair and objective. The Commission took the line of accepting advice from international authorities, such as WHO and IRPA and was committed to work within the internationally accepted criteria for construction of such lines. They also endeavoured to stay in close touch with evolving international standards of good practice and related research.
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    4.4 Clause 64 Report

  186. This report provides a summary of the issues and submissions on the EIS. All of the major concerns are identified, discussed and, I believe effectively, countered with logical, persuasive argument. The Report notes that reviews were conducted and overseen by bodies such as the World Health Organisation, International Radiation Protection Association, Montanna Department of Natural Resources, American Institute of Biological Sciences, Florida Sciences Advisory Commission and the Victorian Department of Health. The Report correctly notes that without exception these reviews have concluded that adverse health effects from typical exposure to power frequency electric and magnetic fields have not been established.
  187. 187. At the time that the Clause 64 Report was published the authors had the benefit of the final report of the Scientific Advisory Panel overseeing the New York State Power Lines project. After some six years of research and 16 separate research projects designed to assess the public health implications of electric and magnetic fields from power lines, this Committee concluded that most of the research studies reported no effects of concern. The main study which had possible adverse public health impact was suggested by a statistical study by Dr Savitz. Both the New York State Power Line Project Scientific Advisory Panel (Ahlbom et al 1987) and Dr Savitz (Savitz et al 1988) considered that the study did not establish any adverse health effects.
  188. 188. The Clause 64 Report notes that the International Radiation Protection Association (IRPA) was in the process of developing exposure limits for 50/60 Hz fields based on the most recent evidence. It also noted that the proposed IRPA limits for continuous general public exposure were above the electric and magnetic field strengths that would be encountered near the proposed transmission line.
  189. Regarding the conclusion of the Clause 64 Report, I believe it is balanced, and while identifying the concerns, notes that, without exception, reviews have concluded that adverse human health effects from power line fields have not been established. It reasonably considered and adopted the conclusions of independent reviewers of research and recommendations of national and international authorities. It also noted that the exposure levels from the proposed power line would be well within future international standards. I agree with the approach taken in this Report.
    Comment 55 by Andrew Marino
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    5.1 Dr Marino’s Report

    I have read the affidavit of Dr Andrew Marino and have the following comments:

  190. On page 2, paragraph 5, Dr Marino suggests that the transmission lines are a highway for the movement of electrical energy. He states that this energy moves through space surrounding the wires, not inside the wires. As described earlier in my affidavit, electrical power is transmitted as electrons of charge which do move through the wires, not the space surrounding the wires. Because of the movement of charge, magnetic fields are created around the wires. The electric fields are created because a voltage is needed to move the current through the wire.
    Comment 56 by Andrew Marino
  191. On page 2 paragraph 8, Dr Marino notes in his Annexures D and E, graphs of the strengths of the magnetic and electric fields respectively, at various distances from the centre of the proposed transmission line. From these figures, the field strengths at the nearest residence or dwelling (180 m away) would be only 1.7 mG magnetic field strength and 80V/m electric field strength. As will be seen in Dr Marino’s report page 4–5 paragraph 12, these field strengths are inconsequential according to most of the biological effects reports that Dr Marino cites.
    Comment 57 by Andrew Marino
  192. On Page 3, paragraph 10, second paragraph, Dr Marino states that there is no indication that a literature review was undertaken concerning the effect of electric and magnetic fields. Although there is not a large amount of literature on the livestock area, the EIS does quote from two reviews and six separate studies. Although not an exhaustive review, this certainly is a reasonable literature review of most of the appropriate articles.
    Comment 58 by Andrew Marino
  193. On page 3 paragraph 11, Dr Marino claims that the EIS should have commenced with a full literature review on the effects of electric and magnetic fields on humans and livestock, reporting all the scientific reports, studies and findings irrespective of their conclusions for or against harmful effects. Noting that scientific studies have been conducted in this area for some 30 years, the amount of literature is vast. The International Non-Ionizing Radiation Committee of IRPA has been reviewing the scientific literature on 50/60 Hz fields for some 10 years and has only just (in January 1990) been able to publish its standard. There are thousands of reports in the literature—it would be impossible for people working on the EIS to complete a full literature review in the same way that WHO (1984, 1987, 1989) have done.
    Comment 59 by Andrew Marino
  194. Dr Marino suggests the authors of the EIS should have categorised the peer reviewed reports and studies according to their significance and the cross-section of both positive and negative reports would be selected and referred to in the EIS for the public to be fully informed and the decision maker to arrive at a balanced conclusion. In his Annexure G Dr Marino mentions 235 papers, 58 of which are quoted in the WHO 1984 or 1987 report or the Graves 1986 report, 25 papers (Dr Marino quotes) are applicable to the field but not quoted in the WHO or Graves publications but these include papers were too late for these publications or were in obscure foreign journals or were written as reports not easily obtained. Other than these papers, the others quoted by Dr. Marino were only of peripheral importance to the field. 152 of Dr Marino’s publications are not applicable to the 50/60 hertz field. These publications include those on radio frequency or microwave fields, bone healing mechanisms, positive value of induced currents, stress or stress-induced effects which were not directly related to exposure to electric or magnetic fields. Of the journals that were not quoted in the WHO or Graves reports Dr Marino only mentions six references that were in peer reviewed journals.

    One has to question how the authors of the EIS could be expected to identify the whole of the scientific literature, put these into peer reviewed reports and studies, categorise them according to their significance, take a cross-section of the positive and negative reports in some objective manner so that a selection could be identified in the EIS for public scrutiny. If it takes the International Radiation Protection Association NIR Committee many years to do this, following a procedure that allowed a balanced objective selection of the literature to be identified, it does not seem possible that the authors of the EIS would be able to undertake such a task in any reasonable amount of time. It is my opinion that one could only expect that, if WHO reports are published that are balanced and objective, these are meant to be referred to and used by various institutions so that the same procedure of selection of the literature does not have to be repeated by all institutions.

    Comment 60 by Andrew Marino
  195. Dr Marino briefly summarises a number of studies in the scientific literature that have reported adverse effects in biological systems exposed to 50/60 Hz fields.

    The first is Kholodov (1966) who found that exposure to static magnetic fields affected brain waves in rabbits. It should be noted that the fields used are static and bear no relationship to the 50/60Hz fields found around transmission lines. Further, this old study was conducted at a time when a more likely explanation for the alteration of brain waves in rabbits was due to interference to the EEG leads by the magnetic fields (optical fibre leads were not available at this time).

    Comment 61 by Andrew Marino
  196. Dr Marino notes Blanchi et al (1973) reported changes in the EEG of guinea pigs exposed to 100 kV/m, 50 Hz field for 30 minutes. What Dr Marino does not note is that Bankoske et al (1976) failed to see EEG changes in chicks exposed to 40 kV/m and Silney (1979) failed to see changes in EEG in cats exposed to 80 kV/m. Further, Lott and Hines (1983) found no consistent changes in the EEG’s of rats exposed for 60 minutes to 60 Hz fields at 9 kV/m. This latter value being more typical of fields found around transmission lines.
    Comment 62 by Andrew Marino
  197. Dr Marino refers to the study of Lot and McCain (1973). This old study refers to effects of continuous and pulsating electric fields on brainwave activity in rats. This is an old isolated report where the result is most likely due to the fact that leads were used that were interfered with by the electric field. The optical fibre leads for this technique were developed later and these fibres were not interfered with by the fields. Also in view of the reports given above it is extremely unlikely that the results of Lot & McCain are real.
    Comment 63 by Andrew Marino
  198. Dr Marino refers to the study of Friedman and Carey (1972). This study was conducted on primates exposed to static magnetic fields and was reviewed in the WHO 1987 report. This study was conducted using strong static fields that bear no relationship to the power lines under consideration.
    Comment 64 by Andrew Marino
  199. The work of Prochwatilo (1976) is noted by Dr Marino. This study identified effects of electromagnetic fields of industrial frequency on the endocrine system. This report is in an obscure journal. Similar experiments have been normal range of variation in animals or humans or may be compensated for in some way so that no change occurs overall. No adverse health consequence of this effect is known.
    Comment 65 by Andrew Marino
  200. Our immune system guards the human body against external agents such as viruses and other antigens. It is the immune system that responds to viral infections to effectively neutralise the effects of the virus and keep the body in good health. Obviously any decrease in immune response could lower resistance to diseases and create a health problem.
    Comment 66 by Andrew Marino
  201. To test the effect of 50/60 Hz electric and magnetic fields on immune response, Winters (1986) performed a series of experiments on dog and human white cells. One experiment examined the immune properties of unexposed white blood cells during exposure to 60 Hz fields. Another study was conducted on cells taken from the body after dogs and human volunteers were injected with antigens (a substance that can stimulate immune response). Different combinations of 60 Hz electric and magnetic fields were used in the studies. However, no significant results were found to suggest that 60 Hz fields could affect immune response.
    Comment 67 by Andrew Marino
  202. It has been suggested that development of cancer could be enhanced if the immune system of the host was suppressed. Precancerous clones could grow undetected. Evidence that 60 Hz electric fields can suppress T-lymphocyte (cells that participate in the body’s immune response) cytotoxicity has been reported by Lyle et al (1988). A 25% inhibition of allogeneic cytotoxicity of the target cell MPC-11 by the murine cytotoxic T-lymphocyte line CTLL-1 was observed when assayed immediately following a haematological data from animals exposed to 50/60Hz electric fields, WHO (1989) identified that many experiments have been conducted and presented a confusing picture. WHO (1989) noted that the occasional reports of positive or negative results in haematological parameters must be carefully evaluated. Often apparent sporadic effects are not statistically significant when appropriate multivariant techniques are used to analyse the data (Ragan et al (1983)).
    Comment 68 by Andrew Marino
  203. Further, Dr Marino does not mention that negative results after low level electric field exposure have been reported by Mathewson et al (1977, 1979). In their study, using careful environmental control (no spark discharges to animals etc.) and appropriate sham exposures (adequate control population), 384 male rats were exposed for 28 days to 45 Hz fields up to 100 kV/m. No consistent reproducable differences were detected in serum protein, lipid or glucose levels; or in differential leukocyte (blood cell) count. In another well designed study in which sources of artifact were carefully eliminated, Ragan et al (1979, 1983) exposed groups of rats and mice to 60 Hz electric fields at 100 kV/m for between 15 and 120 days and examined numerous haematologic and serum chemistry parameters. Although some changes were noted in individual tests, rigourous statistical evaluation of the entire study did not detect any consistent effects of electric field exposure.
    Comment 69 by Andrew Marino
  204. On page 5 Item K, Dr Marino reports the results of Fischer et al (1978). Fischer et al (1978) examined norepinephrine content in brain tissue from rats exposed to 5.3 kV/metre for 21 days. After 15 minutes of exposure, the levels increased rapidly. However after 10 days of exposure a significant decrease in levels was observed when compared to a control group. This result is in sharp contrast to the work of Portet et al (1984) and Portet and Cabanes (1988) who reported no changes in adrenyl epinephrine or norepinephrine in two month old rats exposed for eight hours per day to a 50 kV/metre, 50 Hz field.

    Dr Marino mentions the work of Grin (1978). This paper observed changes from exposure to microwaves which have no relevance to the exposure to 50/60Hz fields.

    Comment 70 by Andrew Marino
  205. Dr Marino reports on page 5 Item L, the work of Andrienko et al (1977). These authors reported altered sperm production in rats following exposure to a 5kV/m field. However this old study published in Russian has not been reproduced in more recently well controlled experiments by Sikov et al (1979, 1984) who exposed rats to uniform 60Hz fields at 100kV/m for up to 30 days and found no effect on reproduction. This has been supported by studies by Rommereim et al (1987) who conducted a very detailed and precise study of reproduction and development in female rats and their offspring during continuous exposure (for 19 hours per day) to 60Hz electric fields at 100kV/m. They found no significant effects of exposure on reproduction. This result was reconfirmed in a later series of studies by Benz et al (1987) who investigated the possible effects of exposure to 60Hz electric and magnetic fields generated by 750kV power lines on pre and post implantation survival in mice. The authors found no overall significant differences in numbers of live implants or numbers of early or late deaths, nor in pregnancy rate.
    Comment 71 by Andrew Marino
  206. On page 6 Items M and N, Dr Marino reports the work of Noval et al (1977) and the work of Giarola and Krueger (1974). These authors report depressions in weight and growth of rats or chicks exposed to electrical magnetic fields. However as mentioned above, more recent well controlled studies have not found any such effects (Sikov, 1984; Rommereim et al (1987); Benz et al (1987)).
    Comment 72 by Andrew Marino
  207. On page 6 Item O, Dr Marino reports his study (Marino et al, 1979) in which he performed mid shaft fractures on rats. He reported that exposure to 5 kV/m fields caused a significant retardation in healing. Marino et al (1979) suggests that repair of bone fracture was retarded in rats and mice exposed to 5 or 100kV/m, 60Hz fields but not to very low (1 kV/m) field strengths. This result was not confirmed by McClanahan and Phillips (1983) who exposed rats to 100kV/m fields and found that bone growth per se was not affected by this exposure. They suggested that exposure affected the rate of healing but not the strength of the healed bone. It is interesting that Dr Marino should raise this question since he is an advocate of using electromagnetic fields for bone repair.
    Comment 73 by Andrew Marino
  208. Dr Marino reports a study by Hansson (1981), where rabbits were exposed outdoors in a substation to 50 Hz electric fields at 14 kV/m from conception to 7.5 weeks after birth. Control rabbits were either protected by a Faraday cage or were kept outside, but away from a measurable 50 Hz field. Histological examination of the exposed rabbits brain tissue by light and electron microscopy revealed changes in the Purkinje nerve cells of the cerebrellum in the brain, with the formation of numerous abnormal cytoplasmic structures (lamellar bodies). However, the exposed animals were severely underweight compared to controls, confounding interpretation of the results. Further, Portet et al (1984) attempted to replicate these experiments exposing rabbits in a laboratory to 50 Hz fields of 50 kV/m for 18 hours per day for six weeks, but did not observe lamellar bodies in the Purkinje nerve cells or any other histological changes in the central nervous system.
    Comment 74 by Andrew Marino
  209. Dr Marino on page 6 Item 13, describes his experiments (Marino et al, 1976, 1980). As mentioned above in very well conducted and controlled experiments these effects have not been reproduced (Rommereim et al, 1987; Benz et al, 1987) to both electric and magnetic fields at the same strength or greater, than that which would occur around power lines.
    Comment 75 by Andrew Marino
  210. Dr Marino makes reference in his affidavit (page 5 item 12h; page 7 items 14a , c; page 8 item 15a; page 11 item 15t; page 12 items 15u, w, x, y; page 13 items 15a3, a4) to a number of reports which identified adverse health effects. These were found to be due to microwave exposure (Serdiuk 1975, Dodge 1970, Zaret 1977, Lester and Moore 1982, Poison and Merritt 1985, Lester 1985, Friedman 1981, Sadcikova 1974, Lancranjan et al 1975, Hamburger et al 1983 and Bini et al 1986). It is well established that exposure to microwave fields produces biological effects in an entirely different way to 50 Hz fields and are in no way comparable. The mechanisms of absorption and interaction are completely different. Addition of these references in Dr. Marino’s Affidavit can only serve to confuse and mislead the reader.
    Comment 76 by Andrew Marino
  211. On page 7 Item B, Dr Marino notes the study of Hamer (1968). This old study found that human exposure to electric fields of 4kV/m altered the subject’s ability to react to the presence of a flashing light. However, the most extensive laboratory experiments on human physiology have been conducted by Hauf and co-workers. They conducted a comprehensive clinical evaluation of over 100 volunteers exposed to brief periods of 50Hz electric fields of 1, 15 or 20 kV/m (Hauf, 1974, 1976). These studies have been reviewed in WHO (1984), (1989). Among the many parameters tested by these researches, the field related effects observed included small decreases in reaction time. The authors in a further study attempted to define accurately the cause of the slight variations. They conducted a study on the effects of 200 microamps applied through surface electrodes. These currents were calculated to equal the displacement currents present in their previous electric field experiments. No alterations in reaction time or EEGs were observed. Hauf thus concluded that the slight effects previously observed in subjects exposed in electric fields were probably due to non-specific excitation effects (Hauf, 1976). These results of Hauf et al were confirmed and extended by Kuhne et al (1978).
    Comment 77 by Andrew Marino
  212. On page 7 Item D, Dr Marino mentions a study of Persinger et al (1975) who studied the reaction time in men and women exposed briefly to low field strength electric fields. Not only is one of these experiments in contrast to the results of Hauf et al mentioned above but also Johansson et al (1973) who were not able to find any significant behavioural changes observed in twenty human subjects exposed to electric fields of 20kV/m (50Hz).
    Comment 78 by Andrew Marino
  213. On page 7, item E. of his Affidavit, Dr Marino mentions the study of Gibson and Marony (1974). These researchers carried out a number of psychometric evaluations of six of the subjects exposed to a 0.1 mT field at 45 Hz for 22.5 hours. No field dependent effects were found on visually guided motor behaviours or on motor coordination. However, significant decrements were found in the performance of a test which required the subjects to complete correctly as many additions as possible within five 1 minute periods. Significant improvements were found in the performance of the test of short term memory which was measured by requiring the subjects to respond either to a visual stimulus presented, or to the visual stimulus 1, 2 or 3 presentations before. The changes in performance were not maintained after field termination and values returned to control levels. Gibson and Marony stressed that these results did not indicate a general effect on cognitive function.

    In a summary report on human behaviour, Hauf et al (1982) reported that reaction time was unaffected by exposure to several hours to a combined 50Hz electric and magnetic field (20kV/m and 0.3 mT). Graham and Cohen (1985) and Graham et al (1987) reported that exposure to combined 60Hz electric and magnetic fields (2 six hour exposure sessions at 9kV/m and 20 µT) had limited behavioural and psychological consequences in twelve healthy adult male subjects. The presence of the 60 Hz field could not be detected, and no effects were observed using a wide battery of sensory, motor, perceptual and cognitive tasks including reaction time, and a time estimation task, on ECG or on mood and activity. Although these authors have found some physiological changes of exposure to the field, they did not reflect any observable changes in behaviour, or in the performance of the tasks themselves. The authors reported that all changes were within normal ranges. Finally, it should be noted that the experiments of Hamer (1968) were at very low field intensities (4 V/m) and at frequencies of 2, 6 or 12 Hz. It is not known whether these frequencies and their effects have any relation to 50/60Hz frequency field effects. Further, the increased reaction times to an audio cue found by Hamer were to exposure regimes which were complex, the data were not presented and the statistical analysis is unclear (Sienkiewicz et al, 1990).

    Comment 79 by Andrew Marino
  214. On page 7 Item F, Dr Marino reports the work of Dumanskiy et al (1977). These are the first to report an increase in blood glucose in human subjects following exposure to 15kV/m fields for 1.5 hours per day for six days. As mentioned above, this study is in direct contrast to the very extensive studies conducted by Hauf et al on large numbers of human volunteers exposed to 50Hz fields up to 20 kV/m. The study is also in contrast to the more recent studies of Sander et al (1982) who found no effects on blood biochemistry in subjects exposed up to 20kV/m electric fields for 6 to 22 hours per day for seven days.

    Even more recent studies of Graham and Cohen (1985) and Fotopoulos et al (1987) who exposed human volunteers to electric and magnetic fields (60Hz, 9kV/m and 20 µT) found no effect on various blood parameters in 12 male subjects.

    Comment 80 by Andrew Marino
  215. On page 7 item G, Dr Marino reports the study by Beischer et al (1973). A total of 10 subjects were exposed to a 0.1 mT field at 45 Hz continuously for 9.8 hours (2 subjects) or for 22.5 hours (8 subjects). Although they were confined to the test facility for seven days, no effects were reported on a number of biochemical and haematological parameters except for a significant increase in mean serum triglyceride levels 1–2 days after exposure. This was partly attributed to hostility between some of the exposed subjects, changes in diet and habits (EPRI 1979). There were no measurable effects on a wide variety of psychological parameters, including EEG, heart rate, blood pressure, respiration rate and temperature. Normal circadian rhythms were maintained and the cardiovascular and neuromuscular reaction to physical stress were normal. The magnetic field did not effect alertness.

    Sander et al (1982); Sander and Brinkmann (1986) exposed human volunteers to 50Hz fields up to 5 mT for four hours and found no evidence of any effect from a large battery of parameters including blood chemistry and blood cell counts, various hormones and enzyme levels, the ECG, or pulse rate. These latter studies were much more extensive than those of Beischer et al (1973). Further, Beischer et al (1973) used magnetic field strength of 0.1 millitesla where Sander et al (1982) and Sander and Brinkmann (1986) used fields up to 5 mT. Rupilius (1976) conducted a study on humans who were exposed for 3 days to 20kV/m electric field at 50Hz and combined this with exposure to a 0.3 mT magnetic field at 50Hz. This author made observations for up to 24 hours after exposure and found no changes in blood chemistry, including triglyceride levels. Similarly, Eisemann (1975) did not show any effects on human subjects exposed for a period of three hours to a conductive current of 200 microamps at 50Hz.

    Comment 81 by Andrew Marino
  216. On page 8 Item H Dr Marino mentions the study of Persinger et al (1985) who found a magnetic field (about 10 gauss—one mT) altered the ability of subjects to process and remember verbally delivered information. This report is in contrast to those of Kuhne (1980), Hauf (1976), Johansson et al (1973) and Sander (1982). It is also in contrast to the recent study of Graham and Cohen (1985) and Graham et al (1987). Even more recently, Stollery (1986), (1987), exposed 76 male volunteers to 500 microamp currents and found that there were no effects on mental capacity, levels of stress or verbal reasoning, vigilance and sustained concentration.
    Comment 82 by Andrew Marino
  217. On page 8 Item I, Dr Marino mentions the studies of Wever (1971, 1974). Wever exposed about 300 subjects either to reduced natural fields or to 10Hz square wave electric fields at 2.5 V/m (not 50/60Hz sinusoidal fields as found from powerlines) and compared effects on the various circadian rhythms with free running values obtained in the presence of natural fields. Wever showed that the applied electric field could synchronise the periods of free running rhythms with the period of the applied field (12 hours on; 12 hours off). However within a week the period of rhythm returned to its free running value. Although no studies have been conducted on sinusoidal 10Hz fields, WHO (1984) notes that Wever’s data are difficult to interpret with reference to electric fields at environmental levels. With a lack of appropriate human experiments, one looks to the results of animal studies. When animals were exposed to 60Hz electric fields up to 100kV/m, effects were found on circadian rhythm in rats and mice (Ehret et al, 1980; Ehret and Duffy, 1983). However at lower field strengths Sulzman and Murrish (1986) exposed squirrel monkeys to 60Hz electric fields up to 39 kV/m and magnetic field up to 0.1 mT in constant light and monitored the free running period of feeding and oxygen consumption. No changes were observed in two monkeys exposed at 2.6 kV/m. However changes were observed in three out of nine monkeys exposed to 26kV/m and in three out of four monkeys exposed to 39kV/m. It is difficult to interpret these results with respect to human exposure.
    Comment 83 by Andrew Marino
  218. On page 8 paragraph 15, Dr Marino mentions the use of epidemiological studies to evaluate effects of electric and magnetic fields on humans. Dr Marino mentions 35 separate studies. However, 10 of these relate to humans exposed to microwaves which bear no relationship to exposure to 50/60Hz fields as discussed previously, and one study by Ericson and Kaffen (1986) relates to exposure to video display terminals where exposure to 50/60 Hz electric and magnetic fields is extremely low. Of the epidemiological studies of both the working and general population, a review of these has been completed by WHO (1989) and the International Agency for Research on Cancer (1990). WHO (1989) indicates reported effects on cancer promotion, congenital malformations, reproductive performance and general health, although somewhat suggestive of adverse health effects, are not conclusive. The International Agency for Research on Cancer states that human exposure to extremely low frequency (ELF, 30–300 Hz) electric and magnetic fields has recently been suspected of increasing the risk of cancer and leukaemia—in particular, acute myeloid leukaemia (AML) but the evidence remains inconclusive. Further, it is stated that all occupational studies to date have lacked direct assessment of exposure levels of ELF electromagnetic fields, and excess risks were not always found in the same occupational group. None of the studies could seriously address confounding by other known or potential leukaemogens. The consistency of the results in several countries and with different occupational groups and study designs is nevertheless notable, and although most used precautional measures, the excesses observed are not likely to be artifactual. This report further states that, exposure to ELF fields occurs in both occupational and residential settings; although both types of exposure may be important, most studies have considered only one or the other. The resultant, lack of precision in exposure assessment may obscure associations between exposure and disease. This aspect of study design is critical when the risk, if any, is likely to be small—and the risk may be undetectable unless care is taken to measure exposures precisely and to minimise sources of bias. The International Non-Ionizing Radiation Committee of the International Radiation Protection Association (IRPA 1990) from its review of the epidemiological studies of both occupationally exposed groups and the general public states that the evidence does not establish that there is a causal link between exposure to 50/60Hz electric and magnetic fields and cancer.
    Comment 84 by Andrew Marino
  219. Dr Marino claims on page 13 in Item 16, that in his opinion, based on the laboratory studies backed up by the epidemiological studies, the electric and magnetic fields, extending laterally 300 metres either side of the proposed 500kV transmission line (Mount Piper to Marulan) can result in alterations in all body systems, including the nervous, endocrine, heart, blood, immune and reproductive systems. Comparing the animal data and human studies as described above and the fact that the nearest dwelling to the proposed Mount Piper to Marulan 500kV line will be exposed to typical fields of 12 V/m and 1.7 milligauss, Dr Marino’s allegations are completely unfounded. His opinions are certainly not backed by the laboratory and epidemiological studies. Dr Marino’s opinions are completely out of line with the WHO (1984, 1987, 1989) studies as well as that of the International Radiation Protection Association (IRPA 1990).
    Comment 85 by Andrew Marino
  220. Dr Marino mentions the study of Nordstrom et al (1983). Congenital deformities were found in 10% of 119 children of sub station workers whereas only 2.7% of children of unexposed workers showed such deformities. When Anderson and Phillips (1984) analysed these data, they had major questions in the interpretation of the results because the highest percentage of abnormal progeny appeared to be related to the type of job, rather that the level of exposure.
    Comment 86 by Andrew Marino
  221. Dr Marino goes into some detail on his theory that electric fields are a stressor on the body. To determine if there is any evidence for such a hypothesis, Stollery (1986, 1987) studied psychological effects of electric currents induced in humans exposed to 50 Hz electric fields of 36 kV/m. To circumvent the perception of hair movement or spark discharge, electric currents (estimated to be below perception threshold) were directly applied to volunteers via a number of small electrodes in order to simulate the current distribution induced by exposure to the external field. 76 male volunteers were exposed to 500 µa (group A) or sham exposed (group B) for 5.5 hours on day 1 (under double blind conditions). A week later the conditions of exposure were reversed. During each session, stress and arousal levels were reported by a mood check list, and psychometric tests of memory attention and verbal reasoning were administered. No obvious or simple mental deficit resulted from the passage of currents; levels of stress were unaffected in both groups, as were verbal reasoning, vigilence and sustained concentration.

    The available evidence suggests that human behaviour is unaffected by exposure to 50/60 Hz electric fields since no effects on simple psychological tests including measurements of reaction times to visual or auditory stimuli, or on the EEG, have been reported from exposure to 50 Hz fields at electric field strengths up to 20kV/m for periods up to one week (Sander, 1982; Kuhne, 1980; Hauf, 1976; Johansson et al, 1973). Further, Graham and Cohen (1985) and Graham et al (1987) reported that exposure to combined 60Hz electric and magnetic fields (2 six hour exposure sessions at 9 kV/m and 20 µT) had limited behavioural and psychological consequences among 12 healthy adult male subjects.

    The only time that humans exposed to electric fields have demonstrated stress reactions is in the presence of repeated spark discharges (Hauf (1982)) with increased nervousness and the inability to continue work (Dino and Zaffanella, 1975).

    Comment 87 by Andrew Marino
  222. If the human studies do not support Dr. Marino’s hypotheses that 50/60 Hz fields may cause stress to the human body, then the animal studies related to testing this hypothesis should be investigated. Of these one can say the following:

    Plasma corticosterone levels are used as an index of stress and can be readily increased by exposure to stressors such as noise. Marino et al (1976) reported decreases in corticosterone levels in mice following a 30 min exposure to a 15 kV/m 60 Hz field. In contrast other authors have reported levels of circulating corticosterone in rats to be unaffected by exposure to 60 Hz fields up to 100 kV/m for one day (Hjersen et al 1980) or for 120 days (Free et al 1981). An extensive and well planned study by Hackman and Graves (1981) found no effect on plasma corticosterone in mice exposed to a 60 Hz field at 25 or 50 kV/m for periods between 5 minutes and 42 days except for a transient elevation (of about one half the magnitude produced by an acoustics stressor immediately following field onset). Quinlan et al (1985) found no increase in corticosterone levels in rats exposed to a 60 Hz field at 100 kV/m for 1 or 3 hours. Portet and Cabanes (1988) exposed young rats to a 50 Hz field at 50 kV/m or 8 hours a day for four weeks as part of a study concerned with the effects of electric fields on growth and development. No effects on the circulating levels of corticosterone was found.

    Comment 88 by Andrew Marino
  223. I conclude from the above that neither the human studies or the bulk of the animal experimentation supports Dr Marino’s hypothesis that electric fields can act as a stressor.
    Comment 89 by Andrew Marino
  224. On page 13 Item 18, Dr Marino states that in his opinion humans and animals living and/or working within 300 metres of either side of the proposed 500kV transmission line are more likely to develop disease than humans and animals that are not within the sphere of influence of the electric and magnetic fields. His reasons on page 14, items 1 and 2, as shown, are not supported by either the animal or human studies. Electric and magnetic fields would exist around the proposed 500kV transmission lines and the field strengths could be generally in line with the annexures D and E of Dr Marino’s affidavit. However the studies in (iv) and (v) referred to in Dr Marino’s affidavit, are not supportive of an adverse health effect as he suggests.
    Comment 90 by Andrew Marino
  225. On page 14 Item 20, Dr Marino criticizes the EIS for drawing analogies between the electric and magnetic fields from transmission lines and the electric and magnetic fields produced by natural sources and household appliances. It is my opinion that such analogies provide useful information to the readers of the extent of field strengths that will be produced by the 500 kV transmission line. For the non-scientific reader, I believe it is useful for them to know the comparative field strengths from domestic appliances and those that would be produced by the transmission line.
    Comment 91 by Andrew Marino
  226. Dr Marino makes a statement that the EIS understates the importance of the development of electromagnetic energy in the treatment of human disease and for other clinical purposes. It is my understanding that an EIS attempts to identify adverse environmental impacts, not effects that are likely to produce beneficial effects.

    Dr Marino notes that weak electromagnetic fields could cause bone growth in animals and humans. This is almost certainly a result of induced currents. It has been recognised for some time that electric fields induce currents within the body and that if such induced currents were high enough, adverse health effects could result. This is the conclusion of the WHO (1987) report and the basis for development of the IRPA (1990) interim exposure limits for 50/60 Hz fields. The fields associated with the Mt. Piper to Marulan line would induce currents well below those that could produce adverse effects.

    Comment 92 by Andrew Marino
  227. On page 15 Item 22, Dr Marino criticizes the EIS for comparing the effect of electric and magnetic fields on humans from household appliances with the effect of electric and magnetic fields on humans from the proposed 500kV transmission line. He claims that such comparison trivialises the effect of electric and magnetic fields from the proposed transmission line. The WHO documents published in 1984, 1987 and 1989, all make comparisons of the electric and magnetic fields emitted from domestic appliances, sources in factories and transmission lines to provide the reader with some comparison of relative strengths of the electric and magnetic fields emitted. This is a perfectly valid way of providing some tangible comparison for readers not familiar with the fields from transmission lines. On page 36 to 39 of WHO (1987), values of magnetic field strength around various appliances are given. These can be compared with those that workers receive from various devices found in industries. As can be seen from these tables, the exposure from high voltage transmission lines is comparable in some cases to domestic appliances and is lower than many occupational exposures.
    Comment 93 by Andrew Marino
  228. On page 16, paragraph 24 of his Affidavit, Dr Marino claims that the value of the WHO (1984) report is minimal because it states that adverse health effects due to ELF electric fields normally encountered in the environment have not been established. He suggests the data contained in the report can equally be interpreted as indicating that not only do biological effects occur from electromagnetic fields, but that they are related to serious health problems in human populations exposed to such fields. This WHO report resulted from an in depth review of the peer reviewed scientific literature and other reports and its interpretation and conclusions were the result of an international task group with expertise in a wide range of disciplines within the ELF field. The conclusions were a consensus agreement and I believe are as authoritative and balanced as could be obtained at the time.
    Comment 94 by Andrew Marino
  229. Dr Marino criticizes the EIS for selectively quoting from the WHO report. As chairman of that WHO Task Group and being heavily involved in the drafting and editing of the report, I can state that the EIS has selected appropriate conclusions that reflect the whole text of the WHO document.
    Comment 95 by Andrew Marino
  230. It should be remembered that the WHO report had as its terms of reference to review the scientific literature in depth, make recommendations from this review, and identify gaps in knowledge where further research should be conducted. Hence some of the conclusions not quoted in the EIS related to these gaps in knowledge and recommendations for more research. The other conclusions not quoted were safety related where workers were warned about high electric field strengths and the possibility of spark discharges that may impair their performance. None of the conclusions missing from the WHO report were really relevant to the EIS.
    Comment 96 by Andrew Marino
  231. On page 19 paragraph 26, Dr Marino refers to the literature which was available at the time that the EIS was published. Having reviewed the list of references that Dr Marino quotes in his Affidavit annexure G, I note that most of these reports are not directly applicable to a health risk assessment of exposure to 50/60 Hz fields since they included papers on microwave and radiofrequency effects, bone healing mechanisms, positive reports on healing by induced currents and stress or stress induced effects (none directly related to electric or magnetic fields). Of the 235 papers listed by Dr. Marino, 58 were reviewed in the WHO or Graves reports, 25 of the 50/60 Hz papers were not reviewed for various reasons—including being too late for the reports, publications in obscure foreign journals or publications in non-scientific or non-peer reviewed journals or not easily obtained. 152 of Dr. Marino’s references are not applicable to 50/60 Hz fields.
    Comment 97 by Andrew Marino
  232. On page 19 item 27 of this affidavit, Dr. Marino claims the EIS did not consider environmental impact, long term health effects, safety to the environment, polluting the environment and measures to take to protect the environment. It may have been implied by the authors of the EIS that by quoting the WHO (1984) report they were in fact reviewing the 250 references it contained. The Graves 1986 report contained over 160 references. These major reviews covered all of the above paragraphs, and were published as authoritative reports on the subject. These reports were published with the intention of covering all aspects of health from exposure to power lines. Dr. Marino is wrong in his contention that the WHO and Graves reports were inadequate for an EIS.
    Comment 98 by Andrew Marino
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    5.2 Dr Liboff’s Report

    I have read the Affidavit of Dr Abraham R Liboff and have the following comments:

  233. Dr Liboff states on page 2, paragraph 5 of his Affidavit that he considers that the magnetic field is the source of low intensity interaction between electromagnetic (EM) fields and living things. By this statement he suggests that the effects found due to electric fields are not of importance or alternatively that the electric field strengths around power lines are sufficiently low that no adverse health effects have been established. This is in contrast to the main thrust of Dr. Marino’s Affidavit where very few reports relating to magnetic field effects are referenced. Dr. Marino is suggesting that the electric field is the source of interaction between EM fields and living things.
    Comment 99 by Andrew Marino
  234. On page 2 of his affidavit, paragraph 6, Dr Liboff mentions that in his opinion research conducted has indicated that there is a coupling between cells and very weak ELF magnetic fields that could give rise to various biological responses. These have been reviewed by the WHO reports (1984 and 1987) as well as the Graves (1986) report. Most of these studies have been conducted on individual cells exposed in culture media or small amounts of biological tissue. These in vitro experiments are conducted to give the experimenter some insight into the mechanisms by which the electric or magnetic fields interact with biological systems. This type of experimentation has only limited applicability to a health risk assessment of these fields since once an effect is found in vitro, it must also be found in vivo to determine if the same effects occur in whole living animals or whether they are masked or made inconsequential in some way.

    This experimentation as well as the evidence suggesting that response of cancer cells to ELF fields is greater than the response of normal cells to the same fields is still very preliminary and has yet to be established. Much of the evidence from experiments suggested so far has come from single laboratories and has not been reproduced by independent laboratories. As indicated earlier in my affidavit, independent replication of results is essential for there to be sufficient established evidence that a health risk assessment can be made.

    Comment 100 by Andrew Marino
  235. On page 3 Item 7, Dr Liboff claims that in his opinion ELF interaction with cells is undeniably real, despite the lack of comprehensive mechanisms to explain how such ultra weak fields could conceivably trigger the biological changes that are observed. The WHO documents have reviewed these mechanisms and as stated above they are still at a very preliminary stage and insufficient evidence is available to make any health risk evaluation. This is also the opinion of the International Radiation Protection Association (IRPA 1990).
    Comment 101 by Andrew Marino
  236. Dr Liboff quotes yet another review the OTA report and makes an unintelligible summary statement from it. This report, (OTA, 1989) reviews the literature and concludes that the available literature is incomplete to make a health risk assessment and recommends that more research be carried out.

    The OTA report is the result of a review conducted by three scientists, Dr I Nair, Dr M G Morgan and Dr H K Florig. The document is a background paper on biological effects of power frequency electric and magnetic fields and was prepared for the office of Technology Assessment for the US Congress. This is in contrast to the WHO reports which are prepared by experts and reviewed by individual scientists and institutions around the world and finally presented to a task group for extreme scrutiny prior to publication.

  237. The following two paragraphs (from OTA page 3) summarise the “feeling” of this report:

    “As recently as a few years ago, scientists were making categorical statements that on the basis of all available evidence there are no health risks from human exposure to power-frequency fields. In our view, the emerging evidence no longer allows one to categorically assert that there are no risks. But it does not provide a basis for asserting that there is a significant risk.”

    This statement appears to be one that takes an each-way bet. Noting that the OTA report was prepared by 3 scientists with the aim of summarising the status of knowledge, one of its prime aims was to highlight the fact that more research is needed before any definitive conclusions can be made

  238. The OTA report further states on page 3:

    “If exposure to fields does turn out to pose a health risk, it is unlikely that high voltage transmission lines will be the only sources of concern. Power-frequency fields are also produced by distribution lines, wall wiring, appliances, and lighting fixtures. These non-transmission sources are much more common than transmission lines and could play a far greater role than transmission lines in any public health problem.”

    This statement is in contrast to those of Dr. Marino and Dr. Delpizzo who claim that high voltage transmission lines are the only significant source of concern.

    Comment 102 by Andrew Marino
  239. On page 3 Item 9 of his affidavit, Dr Liboff refers to the studies of Savitz and Wertheimer and Leeper (1979). In their review, the International Radiation Protection Association (IRPA) (1990) found that the Savitz study was conducted in the same geographical location as the Wertheimer and Leeper study and so could not be said to provide independent support for the Wertheimer-Leeper study. Further the Wertheimer and Leeper study has been heavily criticised by Cole (1987) as a biassed study. Details of the criticisms of Cole are provided in Repacholi (1990).
    Comment 103 by Andrew Marino
  240. On page 4, paragraph 9, second sub-paragraph, Dr Liboff states that the New York State Power Lines Project Final Report states that:

    “with the wire code distribution that Savitz saw in Denver (the figures and the localities are unknown and may vary) and the assumption of a causal effect, this would mean that 10 to 15% of childhood cancer cases are attributable to magnetic fields.”

    It should be noted that this was a worst case assumption and assumes that there were no errors within the Savitz study that would confound the final result. It also means that, if childhood leukaemia occurred at an incidence rate of one case in 10,000, that 15% of the one case in 10,000 would be attributable to magnetic field exposure. However it must be remembered that this is still a preliminary study and much larger studies are needed to determine if this effect is real.

    Comment 104 by Andrew Marino
  241. In the following paragraph, Dr Liboff states that the most recent published study was that of Genevieve Matanoski of Johns Hopkins University in the USA who found that telephone workers have significantly elevated rates of cancer, especially leukaemia. This study has been published only as an abstract to a conference and the abstract itself makes no reference to any result at all. Thus, the elevated cancer risks stated can only be from a presentation that has not received any peer review scrutiny. Hence the results of this study must remain in question.
    Comment 105 by Andrew Marino
  242. Dr Liboff notes that from the Savitz study and increased cancer risk was suggested from exposure to 60 Hz fields in excess of 2.5 mG. He then states (on page 4 item 10 of his Affidavit) that on the basis of the epidemiological studies together with the evidence at the basic cellular level, he formed the opinion that 60 Hz magnetic fields at 1 mG level (and probably lower) constitute a hazard to humans. The basis for this statement is entirely unclear. It is in contrast to the conclusions of WHO (1984, 1987) and IRPA (1990).
    Comment 106 by Andrew Marino
  243. On page 5 Item 12 Dr Liboff refers to a number of references to scientific reports, studies and findings in his literature list. It should be noted that virtually all of these references have been reviewed by WHO (1984, 1987) and Graves (1986). Less than 5 of these reports have not been reviewed by these documents. Of these, a few were abstracts or in reports that were not easy to obtain. Thus it can be concluded that the scientific reports, studies and findings that are suggested by Dr Liboff have already been reviewed by the WHO and Graves documents and thus their conclusions are drawn from the same body of literature.
    Comment 107 by Andrew Marino
  244. Dr. Liboff correctly notes that the WHO (1984) report was on electric fields and not magnetic fields. The WHO (1987) report was on magnetic fields. However, the WHO (1984) report does review the epidemiological studies because at that time it was not known if some of these studies referred to the electric or magnetic fields. Thus Dr. Liboff’s assertion that the WHO (1984) report makes no or inadequate reference to studies on potential hazard from human exposure to low-level EM fields is entirely incorrect (see WHO 1984 pages 79-82).
    Comment 108 by Andrew Marino
  245. On page 5, paragraph 14, Dr Liboff suggests that Dr Graves is not a competent scientist to have completed his review in 1986 for the Victorian Minister for Health. Dr Liboff is unable to recollect hearing any scientific presentations by Dr Graves or having read any of his published works. Perhaps if Dr Liboff had read the WHO 1984 document he would have seen that three of Dr Graves’ scientific publications are referenced. Also in the WHO 1989 document four of Dr Graves are reviewed. Previously, Dr Graves had chaired the Florida Electric and Magnetic Fields Science Advisory Commission to conduct a review similar to that conducted for the State of Victoria. It is without doubt that Dr Graves is a well recognised scientist in the 50/60 Hz field.
    Comment 109 by Andrew Marino
  246. On pages 6-9, paragraphs 15 and 16, Dr Liboff suggests that the EIS does not take account of the studies conducted prior to 1987. He also lists some thirty five references to support his case. However virtually all of the appropriate references that he listed were reviewed by the WHO 1984 and Graves 1986 reports. The WHO 1987 report which also reviews these references and many more reached the same conclusions as the EIS. Thus it is my opinion that Dr Liboff’s case is without any support since the WHO documents and Graves report have reviewed many hundreds more reports from the scientific literature to reach their conclusions.
    Comment 110 by Andrew Marino
  247. On page 6, paragraph 16, second sub-paragraph, Dr Liboff mentions that laboratory evidence exists that ELF fields affect biological functions. He refers to the study of Bassett et al (1974) and the studies of Rodan et al (1978) and Luben et al (1982). Two of these three reports were reviewed by WHO and so were incorporated within the general text of the document. Thus the reports were used to form the overall picture of the field and hence the conclusions of the documents.
    Comment 111 by Andrew Marino
  248. On page 6, item 16, third paragraph, Dr Liboff mentions the paper of Marron et al (1975) who found a mitotic delay in the slime mould induced by low intensity 60 and 75 Hz electromagnetic fields. Such studies are normally conducted to identify mechanisms by which the ELF fields can interact with biological tissues. It is difficult to determine what a consequence an effect on slime mould might have in terms of human exposure. Only after mechanisms of interaction are fully understood can such extrapolations possibly be realised.
    Comment 112 by Andrew Marino
  249. On page 7 first paragraph, Dr Liboff mentions the work of Dr Ross Adey and his researchers. This area of research has been reviewed by WHO 1984, 1987, 1989. It was also reviewed by Graves (1986) and hence the results and conclusions of these reviews have taken this research into account.
    Comment 113 by Andrew Marino
  250. On page 7 second paragraph, Dr Liboff mentions the work of Wilson et al (1981) who found that chronic exposure to 60Hz electric fields affects the pineal function in the rat. Again this work has been reviewed by WHO (1984) and Graves (1986). The report by Sulzman and Murrish (1986) was published as a final report to the New York State Power Lines Project and was not available at the time of publication of the WHO (1984) or Graves (1986) reports. Sulzman and Murrish (1986) exposed squirrel monkeys to 60Hz electric fields up to 39 kV/m (with a concomitant magnetic field of up to 0.1 mT) in constant light and monitored the free running period of feeding and oxygen consumption. No changes were observed in two monkeys exposed to 2.6 kV/m; however changes in both periods were found in three out of nine monkeys exposed to 26 kV/m and in three out of four monkeys exposed to 39 kV/m; these showed a lengthening of period but without any evidence of desynchronization between the rhythms. It should be noted that the continuous exposure to electric fields from the proposed 500 kV power line will be much less than the 2.6 kV/m found to show no effect in this set of experiments.
    Comment 114 by Andrew Marino
  251. On page 7 third paragraph, Dr Liboff mentions the studies of Delgardo et al (1982) and the study of Ubeda et al (1983) who found that very low level magnetic fields seem to be able to disturb normal development in chick eggs. Dr Liboff does not mention the study of Maffeo et al (1984) who exposed fertilised chick eggs to magnetic fields of amplitudes 1.2 or 12 microtesla (the same magnetic field strengths that were used by Delgardo and Ubeda). Maffeo et al found no significant differences between the exposed, sham exposed and untreated control groups. Similarly, Sisken et al (1986) and Sandstrom et al (1987) did not find any effect of electric or magnetic fields on either chick embryos or fertilised chick eggs. In an effort to resolve the differences in these observations, a large scale study was set up by Berman et al (1988) to investigate the effect on chick embryos of exposure to low level pulsed magnetic fields. Unfortunately the results of this study (called the Hen House Study) produced conflicting results in that only two out of six laboratories conducting the study found an increase in abnormal embryos from the treated group. Cameron et al (1985) observed that fish eggs suffered physiological perturbations when exposed to 60 Hz magnetic fields. Also Hellman et al (1984), which was an abstract at a conference, showed that macrophage function was altered by exposure to 15 Hz repetitive signals. Greater relevance to human health comes from experiments looking at effects on mammalian development. Tribukait et al (1987) reported an investigation of developmental effects on mice exposed to pulse magnetic fields for the first fourteen days of gestation. Magnetic fields of amplitude 1 microtesla or 15 microtesla were used and no effects on the number of implantations or on post-implantation survival in the exposed group compared to the controlled group were found. No differences in malformations in the offspring were found when the analysis by litter rather than individual foetuses was performed. Similar studies performed by Stuchly et al (1988) who exposed female rats for two weeks prior to and throughout pregnancy for seven hours per day to magnetic fields of intensities 5.7, 23 or 66 microtesla found no significant increase in the number of exposed foetuses showing external malformations. Similarly, Brinkmann et al (1988) reported a lack of effect of exposure of rats throughout gestation to relatively intense magnetic fields of 15 mT at 50 Hz on a number of foetuses with abnormalities.
    Comment 115 by Andrew Marino
  252. As Dr Marino had done previously, Dr. Liboff has quoted a few studies from the scientific literature that reported adverse effects. However, he does not quote any of the reports which attempted to replicate these positive results and failed. This is misleading and leads to an unbalanced view being presented.
    Comment 116 by Andrew Marino
  253. On page 7 Dr Liboff under the title “Epidemiological Studies” again reviews some of the human studies which suggest that there is a link between exposure to power lines (magnetic fields) and cancer. This has already been reviewed by WHO (1984, 1987, 1989), IRPA (1990), Coleman and Beral (1988), Ahlbom et al (1987) and the International Agency for Research on Cancer (1990) all of which found that the evidence from epidemiological studies remains inconclusive. The laboratory studies certainly do not support the weak epidemiological evidence that exposure to 50/60 Hz fields is associated with an increase in cancer.
    Comment 117 by Andrew Marino
  254. On page 8, under the heading “Biological and Physical Mechanism”t; Dr. Liboff mentions the work of Dr Goodman. Goodman and Henderson (1986, 1988) and Goodman et al (1987a, b) who found effects of time varying magnetic fields on cellular transcription. He also mentions his own work (Liboff et al 1984) and the effect of weak magnetic fields on DNA synthesis. Dr. Liboff mentions that his results were confirmed by Takahashi et al (1986), however he does not mention that Trent (1987) was unable to find any significant increase in gene expression in a human carcinoma cell line after exposure to 60 Hz magnetic fields up to 200 µT. This line of research is very preliminary and certainly has not lead to the suggestion of public health impact. It would need to be extended before one can determine if such effects are found in humans and animals.

    The work of Goodman, Liboff and others has been reviewed by Graves (1986) and WHO (1987) and so the possible impact of this research has been taken into account.

    Comment 118 by Andrew Marino
  255. On page 9 second paragraph, Dr Liboff mentions that he began to review possible connections between ELF biological literature and the epidemiological evidence for leukaemia by Wertheimer and Leeper and Milham. The publication he quotes is his reference number 27 (Liboff and Kaplow, 1984). This was published as an abstract to the Bioelectromagnetic Society conference and to my knowledge has not been published in the peer review literature. Dr Liboff also mentions that at the Bioelectromagnetic Society meeting in 1984 that Dr Blackman had presented results which tended to support a resonance-like hypothesis that he had on mechanisms of magnetic field exposure to biological tissues. At the Bioelectromagnetic Society meeting in June 1990, Dr Blackman presented data to suggest that his experiments were now in doubt because he had not kept the temperature of his exposed samples constant throughout the experiments.
    Comment 119 by Andrew Marino
  256. On page 9 item 17, third paragraph, Dr. Liboff describes his hypothesis that ions undergoing membrane transport in channel proteins may be enhanced or retarded as a result of a cyclotron resonance interaction, influenced by the frequency of the AC field, ionic charge to mass ratio, and the intensity of the global DC magnetic field (Liboff 1985). The cyclotron resonance ion hypothesis has been criticized on several grounds (Halle 1988):

    (a) The hypotheses assumes that unhydrated ions exist in the cell membrane whereas ions in bulk solution carry a shell of water requiring great additional amounts of energy for its removal.

    (b) The hypothesis assumes a collision free environment for the ion, whereas the motion of ions in a liquid is highly damped by frequent collisions that would preclude resonant motion at low frequency.

    (c) Under the constraints of motion in a helical channel, the static magnetic field provides no force on the ion and cannot effect its path in the direction along the magnetic fields (parallel to a channel).

    In short the cyclotron resonance model proposed by Dr. Liboff has been shown by Halle (1988) to violate the laws of classical mechanics.

    Comment 120 by Andrew Marino
  257. On page 10 item 18 of his Affidavit, Dr. Liboff notes the work of Winters and Phillips (1984a, b) and the work of Phillips et al (1986). These researchers reported that 60 Hz magnetic fields caused changes in surface antigens of human cancer cells. However Dr. Liboff does not report that in replicate experiments by Cohen (1987) these results were unable to be reproduced. Further, that the Scientific Advisory Panel of the New York Power Lines project reviewed the laboratory of Phillips and Winters and found a number of methodological flaws with the technique used and errors in the conclusions reached.
    Comment 121 by Andrew Marino
  258. On page 10 Item 19 third paragraph, Dr Liboff suggests that to properly consider whether electric and magnetic fields from the proposed 500 kV transmission line are harmful to health of humans and livestock, all relevant literature should be assessed and understood. The EIS document relied on the WHO (1984) and Graves (1986) reports. As stated previously in my affidavit, these documents were considered to be authoritative as sanctioned by both the Federal Government and State Government of Victoria. These documents did assess the relevant literature and drew conclusions that were in line with all major reviews and so the EIS has completed the task that should be assigned to such a document. Dr Liboff has not presented any evidence that has not already been reviewed by these documents. He has not justified his conclusions that the EIS ignored some well known scientific literature that was available prior to February 1987.
    Comment 122 by Andrew Marino
  259. On page 10 last paragraph, Dr Liboff claims that the EIS is inadequate because it relied on the WHO (1984) report and the Graves report (1986). As mentioned above, these documents were considered authoritative and were meant to be relied on.
    Comment 123 by Andrew Marino
  260. On page 11 Dr Liboff claims that the EIS makes no specific reference to any of the well known peer reviewed authoritative studies which are listed in his literature list. As mentioned previously, the WHO (1984) and Graves (1986) reports have already reviewed virtually all of the literature list that Dr Liboff provided in his affidavit.
    Comment 124 by Andrew Marino
  261. As indicated above, Dr Liboff has not provided any new evidence to suggest that the EIS is inadequate, unbalanced or has not completed a detailed enough review of the literature to reach its conclusions.
    Comment 125 by Andrew Marino
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    5.3 Dr Delpizzo’s Report

    I have read Dr Vincent Delpizzo’s affidavit and have the following comments:

  262. On the first page, paragraph 3 of his affidavit, Dr Delpizzo states that, in his opinion, the EIS does not adequately deal with the hypothesis that exposure to magnetic fields from transmission lines may play a role in the incidence of cancer in humans. From his statement, Dr Delpizzo (in agreement with Dr. Liboff) believes that the magnetic field from transmission lines may be the active agent on biological systems and not the electric field (in contrast to the belief of Dr Marino).
    Comment 126 by Andrew Marino
  263. The use of the word “hypothesis” to describe the situation regarding cancer incidence and exposure to 50/60 Hz fields is entirely correct. Scientists have performed and are currently performing a range of experiments to test this hypothesis because it has not been established or confirmed that these fields are associated with an increased cancer incidence in humans. Since the EIS can only deal with the facts or what is known about health effects from exposure to 50/60 Hz fields it has used the authoritative reports of WHO (1984) and Graves (1986) to do this. It has also alerted people to the fact that some scientists were concerned that exposure to 50/60 Hz fields may be associated with an increased cancer incidence, but that the work is still preliminary.
    Comment 127 by Andrew Marino
  264. In summary, Dr Delpizzo suggests that:

    (i) magnetic fields may be the only concern in terms of cancer risk, and not electric fields;

    (ii) by reference to the “hypothesis,” it has not been established that magnetic fields play a role in the incidence of cancer in humans.

    One can only conclude from the above that since electric and magnetic fields are the only active agents of non-direct contact with transmission lines, Dr Delpizzo believes that no cancer risk has been established from 50/60 Hz fields. His affidavit deals only with the epidemiological studies suggesting a relationship between exposure to magnetic fields and cancer, and the EIS did alert people to this research. Overall his affidavit establishes no scientific basis for the conclusions he reaches regarding the EIS and Clause 64 report.

    Comment 128 by Andrew Marino
  265. On page 2 Item 4 of his affidavit, Dr Delpizzo criticises the EIS for not making any specific reference to research, studies, reports or findings which link magnetic fields to cancer in humans. As stated previously, both the WHO (1984) and Graves (1986) reports do make specific reference to this research area. Since both were confirmed as authoritative documents to be relied on, then I believe that Dr Delpizzo’s statement is not correct.
    Comment 129 by Andrew Marino
  266. On page 2, paragraph 66 of his affidavit, Dr Delpizzo mentions 18 epidemiological studies that suggest a correlation between presumed exposure to magnetic fields and cancer incidence in humans. It should be noted that of the 19 studies mentioned, only two have not been reviewed by the WHO (1984, 1987) or Graves reports. The two that were not reviewed were too late for these publications. Further, the EIS reached the same conclusions as all of these reports.
  267. Dr Delpizzo criticizes the EIS by saying that all of the epidemiological studies he referred to reported a statistically significant correlation between presumed exposure to magnetic fields and cancer. It should be paragraphed out that many of the earlier studies were published as letters to the editor (not peer reviewed) and were cancer registry studies where a causal link was impossible to determine. Cancer registry studies could only correlate the type of cancer causing death and the person’s occupation at death. In no way was it possible to identify the carcinogenic agent. Further, although the studies suggest a correlation between cancer and presumed exposure to magnetic fields (because workers had electrical occupations), the correlations were not with the same cancers. In fact some studies correlated with, for example, leukaemia, while others correlated not with leukaemia but with central nervous system tumours. There is a lack of consistency in the results. Thus Dr. Delpizzo’s statement on page 3, second paragraph, criticising the EIS statement is not correct.
    Comment 130 by Andrew Marino
  268. The epidemiological studies are very confusing since there are many positive and negative results. All of the studies conducted so far suffer from lack of statistical power and inability to quantitate the exposure of people to magnetic fields. Studies are in progress which will address these shortcomings.
    Comment 131 by Andrew Marino
  269. On page 3 last paragraph of Item 7, Dr Delpizzo criticises the EIS as making a statement that indicated an inadequate familiarity with the pertinent relevant literature because he felt that the probability of the association between magnetic fields and cancer being due to chance alone in 19 out of the 28 studies published before 1987, is exceedingly small. What Dr Delpizzo has consistently failed to indicate was that these studies are methodologically flawed and were inadequate to establish a casual relationship as discussed above.
    Comment 132 by Andrew Marino
  270. Dr Delpizzo notes (page 3 item 8) that the EIS makes no reference to the existence of the dose response relationship evident in the two Wertheimer and Leeper (1979, 1982) studies and the Savitz et al (1988) report, and to a lesser extent, the Tomenius (1986) study. Properly, the EIS makes no reference to this dose response relationship because there is virtually no evidence for one in any of the reports. The Savitz study and Wertheimer and Leeper (1979) study has been criticized as being biased by Cole (1987) as reported in my review (Repacholi 1990). Further, in February 1987 many scientists felt, as they do at present, that confounding factors from these results have not been eliminated. For example, in a report by Savitz and Feingold (1990) an increased incidence of cancer has been associated with increased traffic density near residences. Thus one might suggest that the increased cancers suggested in the 50/60 Hz studies could be due to exposure to benzene from exhaust fumes from cars since in residential areas powerlines tend to follow major roads. There are many uncertainties in the epidemiological studies that need to be resolved before the situation becomes clear. It should also be noted that the Scientific Advisory Panel for the New York Power State Power Lines project reviewing the Savitz study stated that its study did not establish that a causal relationship existed between exposure to 50/60 Hz field and cancer incidence. The study merely strengthened the hypothesis and so larger studies were necessary.
  271. On page 4 Item 9, Dr Delpizzo states that in his opinion the last sentence of paragraph 2 on page 177 of the EIS, was no longer an acceptable statement as at February 1987 because of the peer reviewed studies number 28 and 30. These studies were of Savitz et al (1986) and Kaune et al (1986). Both these reports were contractors’ reports to the New York State Power Lines Project. Neither of these studies is peer reviewed. Further, both studies were produced to the New York State Power Lines Project in 1986 and were most likely unavailable to the authors of the EIS as has been stated previously. Even if the Savitz study had been incorporated into the EIS, the criticisms of the study would mean the EIS conclusions would not alter.
  272. On page 4 item 10 Dr Delpizzo agrees with Dr Liboff that the electric field may not pose a hazard. This is in contrast to the belief of Dr Marino. Dr. Delpizzo has not produced any evidence to establish that fields from the proposed transmission line will pose a threat to public health. As he states, it is still a hypothesis.
  273. On page 5, first paragraph, Dr Delpizzo notes that some of the epidemiological studies that report no statistically significant association between magnetic field exposure and cancer in humans can also be shown to have insufficient statistical power or flaws that may account for their inconclusive outcome. Dr Delpizzo is correct in this and, as I stated previously, none of the epidemiological studies have sufficient statistical power to provide a definitive result. This is why there is presently a number of large studies in progress worldwide.
  274. Dr Delpizzo suggests that the negative studies are not good studies, but that the positive studies may be more reliable. It is a scientific fact that it is impossible to prove that something does not occur (negative result). All one can do to show a negative result is accumulate sufficient research evidence to support the case that no effect occurs.
  275. On page 5 Item 11, Dr Delpizzo makes a number of comments about the Clause 64 report of the Commission dated April 1988.

    (1) Distinction between High Voltage and High Current

    The paragraph that Dr Delpizzo has failed to mention is that the Clause 64 report was attempting to indicate that there was a distinction between high voltage and high current since high voltage is associated with electric fields and high current is associated with magnetic fields as described earlier in this affidavit. Dr Delpizzo does correctly state that there is no physical distinction in the nature of the magnetic fields created by high voltage transmission lines and ordinary street wiring. However, he should have mentioned that there is no physical distinction in the nature of the magnetic fields created by high voltage transmission lines, ordinary street wiring or domestic appliances as referred to in the OTA (1989) report mentioned earlier.

    (2) and (3) Wertheimer Study

    On page 6 second paragraph Dr Delpizzo indicates that although it is true that there is no concrete evidence that coding carried out in 1976 reflects exposure in the 1950s there is no reason to believe that generally this is not true. Normally a scientist would want to obtain evidence that wire coding carried out in 1976 did reflect exposure in the 1950s before they believed this.

  276. On page 6 paragraph 3, Dr Delpizzo states that:

    “...errors made in classification of subjects always tend to reduce the estimate of risk, unless the mis classification is non-random. To believe that the association in the Wertheimer and Leeper studies is artifactual and due to inadequate assessment of past exposures is to believe that the number, size and proximity of power lines generally increased over the years for cancer cases and decreased for non cancer control subjects.”

    As has been stated previously the Wertheimer and Leeper (1979) study has been criticised severely by Cole (1987) for being biassed. Thus it does not matter how subjects were classified.

  277. On page 6 No 4 (Physiological Responses) Dr Delpizzo claims that the statement made in the Clause 64 report which gives an analogy between biological effects from normal activities and indicates that because biological effects are reported, these do not necessarily have a consequence to overall health. I believe that giving an analogy such as this to simplify a highly technical area is entirely valid. I quite disagree with Dr Delpizzo’s statement that it is not a valid scientific analogy and is misleading.
  278. On page 7 No 5 (Dr Adey’s work) the statement in the Clause 64 report implies that the work of Dr Adey is from in vitro experiments conducted on cells or pieces of tissue and that unless mechanisms of interaction of the exposing fields are determined, then it is impossible to extrapolate such results to human exposure. Thus the statement that if effects do occur “the body may simply adjust to the new environment” is quite a reasonable statement until similar studies are conducted on animals to determine if the effect occurs in these animals.
  279. On page 7 No 6 (Fields from Household Appliances) Dr Delpizzo claims there is a substantial difference between emission and exposure where exposure is a function of the subject’s position with respect to the source and of the time spent at that position. This statement does not have any foundation whatsoever since the concept of “dose” has not been established for 50/60 Hz fields. He further states that to compare the exposures due to a kitchen appliance to chronic exposure due to power lines is in his opinion absurd and misleading. However he does not say why and what the differences are since both produce magnetic fields albeit for different periods of time. Further, his statement is contrary to the OTA (1989) report which was quoted earlier. Also, the WHO (1984, 1987) reports used the same analogies so that the non-expert reader will have some idea of the strength of fields from various appliances and compared them with those fields from power lines.
  280. On page 7 No 7 (Sources of Magnetic Fields) Dr Delpizzo states that high voltage transmission lines are the most powerful source of chronic magnetic field residential exposure. However at 180 metres from the proposed line, both the electric and magnetic fields will be at strengths much lower than many household appliances as shown in the WHO (1984 and 1987) documents.
  281. On page 8 Dr Delpizzo states that the Fulton et al (1980) study was seriously flawed. This is correct. However, as mentioned above all epidemological studies have serious shortcomings which preclude a definitive result.
  282. Dr Delpizzo (on pages 8-12) makes comments on various of the epidemiological studies which have already been commented upon. However, criticisms in the methodology and flaws in technique and design remain, so that the epidemiological evidence does not provide a body of support to indicate that there is an association between exposure to 50/60 Hz electric or magnetic fields and cancer. Further, there is little or no support from the laboratory studies for the human studies giving a positive result.
  283. On page 12 Dr Delpizzo suggests there is no simple relationship between electric power consumption and environmental magnetic fields, and that the leukaemia death rate is a function of many factors which accounts for its large variation over the past 70 years. While it is true that the death rate from leukaemia will be a function of, among other things, medical treatment available at the time, the incidence of leukaemia should bear a direct relationship to the use of electric power, if indeed exposure to electric or magnetic fields from powerlines is associated with an increased leukaemia incidence. From my information the variation in the incidence of leukaemia has varied very little over the past decades while power consumption has increased very significantly.
  284. On page 13 second paragraph Dr Delpizzo states that the Clause 64 report relied on reviews that were outdated. The most recent review is that of the International Radiation Protection Association (IRPA 1990) which proposed interim guidelines on exposure limits to 50/60 Hz fields. The rationale for these exposure limits for both general public and occupational exposure was given in the text of this affidavit and its conclusions are essentially the same as those in the Clause 64 Report. Further, in the United Kingdom, the National Radiological Protection Board issued a document (NRPB 1989) which essentially came to the same conclusions as the IRPA.
  285. In summary, Dr Delpizzo has not presented any evidence that would negate the conclusions reached by the EIS or the Clause 64 report since these conclusions are still in line with all major reviews conducted to date. Further, Dr Delpizzo does not mention that with the weak, confusing epidemiological evidence there needs to be support from animal studies. This support is not evident from the research available. The EIS and Clause 64 reports reasonably relied on the WHO and Graves reports which were seen to be authoritative, reliable and accurate.
    Comment 133 by Andrew Marino


  286. From my knowledge on the currently available scientific literature I conclude that persons living or working near the proposed transmission line would not suffer any adverse health effects due to exposure from the 50 Hz fields. The current concern is that there is a possibility that exposure to 50 Hz magnetic fields may be associated with an increased incidence of cancer. I have recently completed a review of the literature on this (Repacholi 1990) and submit that, to date, there is no established link with cancer from exposures to fields typically found near transmission lines.
  287. Based on the field levels likely to be encountered near the proposed transmission line, as set out in the table on page 206 of the Clause 64 report (Appendix C), I can say that:

    (a) both the short term and continuous levels are below the limits set by IRPA and NHMRC; and

    (b) in my opinion, people or livestock living or working near the line will not suffer any adverse health effects due to the line's electic and magnetic fields.

Affirmed and Declared at Sydney

before me (s) S. Hebbert, Solicitor

Date: 11 July 1990

(s) M. Repacholi

Comment 134 by Andrew Marino
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SIKOV, M R, ROMMEREIM, D N, BEAMER, J L, BUSCHBOM, R L, KAUNE, W T, PHILLIPS, R D, (1987), Developmental studies of Hanford miniature swine exposed to 60 Hz electric fields. Bioelectromagnetics 8: 229-242.

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Andrew Marino’s Comments on the Testimony

COMMENT 1: Repacholi was hired by the Australian power company because he would say what the company needed saying, irrespective of considerations involving morality or truth. Repacholi could count on the fact that he would not undergo any significant cross-examination by the trial lawyer who represented the homeowners because he was ignorant of the scientific issues and bereft of any desire to learn the science of powerline electromagnetic fields (EMFs).

Repacholi wanted to win his case. Scientific truth, and the morality of involuntarily exposing other human beings to a carcinogenic agent were simply not pertinent considerations.

This comment, and those provided below constitute the thrust of the cross-examination that ought to have been conducted. Had Repacholi been effectively cross-examined, the court would have seen him for what he was, a greedy opportunist whose testimony was no more than a web of lies, distortions, and half-truths.
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COMMENT 2: These paragraphs are the key to understanding how someone as ignorant as Repacholi could rise to the position of EMF boss at WHO, and thereby produce worldwide misery. The legal structure in Australia, as in essentially all countries in the world whose legal system is based on the English common-law system, allows someone with a Ph.D. to make knowledge claims without ever forcing the witness to explain how he knows what he claims to know. The Australian legal system, much like that in America, more or less presumes that a man with a Ph.D. “knows.” To trigger this automatic respect, which allows the witness to testify as if God had told him the truth of the facts that he recounts, the witness needs to establish that he is a “scientist.” Methodologically, this is accomplished by listing the number of times and the different ways in which the witness has functioned as a scientist, or at least apparently so. Matters such as what exactly the witness did, on whose behalf, for what remuneration, with what degree of skill, are usually not considered by the court to be pertinent to the witness’ task. The witness is allowed to simply list things done, like Homer listing the ships that sailed for Troy. From this list the judge inferred that Repacholi was a scientist, and therefore that whatever he said constituted “knowledge.” Repacholi did not invent this structure, but he exploited it magnificently.
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COMMENT 3: The material in paragraphs 26–52, which consists of a tutorial dealing with the elementary physics of EMFs, was entirely irrelevant in the lawsuit. In almost all lawsuits involving health hazards from high-frequency or low-frequency EMFs, such didactic information has no legal relevance. Nevertheless it sounds scientific, and was included by the lawyer who presented Repacholi to elevate his stature and make it easier for him to mount a defense of their client’s interests.

In an ordinary legal case, irrelevant material is stricken following an objection by the adverse party. In EMF cases such an objection is rarely made because the fact that the material is irrelevant is almost never appreciated by the judge or the lawyers who represent the homeowners. The strategy of turning a courtroom into a classroom on the elementary physics of EMFs was invented by the attorneys for the power industry. Repacholi’s willingness to include this material in his testimony is an early indication that he doesn’t know what evidence is important, doesn’t care, or both.
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COMMENT 4: The paragraph is deceptive, like a shell game at a carnival. Repacholi argues that tumor development “appears” to require a particular series of steps. Soon he will begin talking as if what “appears” to be true is actually true. That is, the distinction between his unsupported opinion (the way something “appears” to him) and the way it “appears” to someone else will be completely glossed over, and in the rest of his testimony he will assume that tumor development in humans “requires...”

The perspective from which the paragraph was constructed is that the way cancer comes about is known, namely that it involves initiation, and promotion. Subsequently, he will present evidence that EMFs don’t initiate and don’t promote, allowing him to conclude that they don’t cause cancer. What he obscures is that there is no reason to believe that the initiation-promotion model applies to all human cancers, or even to a majority of human cancers. Actually, all that we know is that “initiation/promotion” applies to is an animal model developed by Boutwell more than 40 years ago. Consequently, even if it were the case that EMFs were neither initiators nor promoters, it would not follow logically that they didn’t cause cancer.

The general structure of Repacholi’s arguments are as follows:

If EMFs cause disease, they must do x.

EMFs don’t do x.

Therefore EMFs don’t cause disease.

In each case, the truth is that Repacholi’s premise is no more than gross speculation. It describes the way he wants the world to be, not as it is.
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COMMENT 5: The first sentence is a tautology because it says only that stimuli that don’t do anything (below threshold), don’t do anything (do not promote). Nevertheless, in a courtroom, it sounds as if it actually means something. The rest of the paragraph applies solely to Boutwell’s model, but that limitation is obscured here and in the rest of the testimony.

Reasoning from Boutwell’s model is a common tactic by power-company experts; Boutwell himself has done it several times to exonerate both power-frequency and high-frequency EMFs. In this case, the power company hired Boutwell and Repacholi and, like a mutual admiration society, they cited one another as authority for their respective opinions.
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COMMENT 6: Evidence that a particular EMF was not positive in the Ames test is not probative (evidence tending to make a proposition more likely than not to be true) with regard to the issue in the case, which was whether powerline EMFs were health risks. In a rational adjudicatory proceedings, this kind of nonsensical reasoning would be excluded. One reason that almost never happens is that experts like Repacholi are more clever at constructing such arguments than judges and lawyers for plaintiffs are at recognizing they are being deceived, because industry experts are almost never effectively cross-examined.
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COMMENT 7: Repacholi exonerates EMFs because some EMF reports “...did not cause...,” “...did not alter...,” the investigators were “...unable to detect...,” “...could not demonstrate...,” found “...no increases in...,” and because “no effects were found....” However, (1) he ignores the large number of published studies that reported exactly the opposite results; (2) he disregards the issue of bias in the negative reports that he cited (that the investigators working for a power industry had a vested interest in not finding anything that would be inconsistent with the public posture of the power industry; (3) he obfuscates the fact that negative studies have almost no scientific value (except in very specialized circumstances not pertinent here). Repacholi’s exoneration is breathtaking in its over-broadness, because there are numerous conditions under which low-frequency fields have been reported to damage DNA.

Repacholi’s argument in paragraph 58 is vacuous and misleading. What does it mean to say that studies “in general” “have indicated” something? Are we to understand that some reports described EMF mutagenicity and others didn't but that the number of the latter is somehow outweighed by the former in quantity or quality? The reality is that there are some conditions in which fields have produced mutagenic effects, and others in which they haven’t. There simply is no objective “in general,” no “bottom line.”

Everything in Section 2.6 is irrelevant, because nowhere in the case was it alleged that 50/60-Hz fields damaged DNA or caused initiating events in cells. The allegation in the case was that the fields cause cancer, which is a completely different proposition.
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COMMENT 8: Paragraph 62 is an instantiation of the deception mentioned earlier. The initiation/progression model of reality has actually become reality for Repacholi. Thus, he argues: If powerlines cause cancer they must initiate or promote, but they don’t initiate, so the only other possibility is that they promote. He has already turned down the wrong road for scientific reasoning, so nothing that follows makes any sense. Additionally, the topic under discussion is legally irrelevant, so this testimony is defective in two dimensions.

From a historical perspective, the general pattern for EMF research is that there is an initial report by a scientist, usually unconnected with any EMF industry, that reports a positive effect of the fields on the system under study. Then, the industry enters into secret research contracts with investigators whose results invariably contradict the initial report. In subsequent court cases, someone like Repacholi is hired to perfect the argument that X reported an effect but Y could not replicate the effect, from which the conclusion drawn is that X was wrong. The argument is logically nonsensical, it is built on the assumption that what comes later is always better than what came earlier, and it ignores the fact that the later work is invariably larded with industry bias. This is the structure of almost every argument that comes from Repacholi’s mouth.

Cohen (1987) found exactly what the Power Authority of New York paid him to find, namely data that put the work of Phillips into issue. With the exception of power-company lawyers and their witnesses, no one else would normally see the Cohen report, which is not a published, peer-reviewed study.

One sophistic device that Repacholi has perfected far beyond the level of any other power-company expert that I have encountered in my years of dealing with the issue of EMF health hazards is the technique of the selective reference. In paragraph 64, for example, Repacholi cites Winters (1986) so that it appears his study is adverse to that of Phillips, which is not true. Winters and Phillips have published together. Their work is mutually supportive, not mutually contradictory.

Repacholi’s citation of Thompson (1988) in paragraph 65 is grossly misleading, because it suggests that the group of investigators made a sincere and independent effort to evaluate the biological effects of powerline EMFs, which is far from the case. The major player in the group was Sol Michaelson who, along with Herman Schwan, were probably the two most myopic investigators in the history of EMF bioeffects research. They both believed to the depths of their souls that powerline EMFs were harmless—Schwan on the basis of cockamamie calculations for which he was famous, and Michaelson, a veterinarian, on the basis of enormously crude experiments.

We know that microwaves can cook tissue; Sol Michaelson was the person who made that discovery. One can read in the published literature his descriptions of animals as they were cooked alive. He describes the change in core body temperature, the oozing of fluids from the eyes and various orifices, and the other physiological sensations associated with being cooked alive. In Michaelson’s perspective, a field that failed to produce a “thermal burden” was safe. Since most investigators are agreed that powerline EMFs do not produce a “thermal burden” it follows on the basis of Michaelson’s twisted logic that powerline EMFs are “safe.” When someone proceeds from this perspective, it is certain that the experiments he performs will substantiate his point of view, and that’s exactly what happened with every experiment Michaelson ever performed. To cite Michaelson as support for the proposition that powerline EMFs are safe is simply absurd.

From a scientific perspective, the reports by Thompson and Frazer are rigged industry-controlled research that deserves to be ignored in their entirety. From a legal perspective one might wonder about the credibility of a witness such as Repacholi who (1) introduces an irrelevant topic to a case; (2) analyzes it on the basis of faulty scientific reasoning; (3) supports his view based on only a selected sub-sample of the relevant scientific literature; and (4) employs a sub-sample that consists entirely of industry controlled research. Sadly, Repacholi’s credibility was never attacked by the cross-examining attorney.
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COMMENT 9: There had been research as of the date of this testimony that reported an association between 50/60-Hz fields and gene expression in higher order animals. Repacholi might not have agreed with it, nevertheless, it existed, contrary to what he told the court under oath.

The last sentence in paragraph 73 densely packs (1) a judgment based on a subjective term, (2) an assertion of an inapplicable standard, and (3) an overt, unjustified value judgment. The phrase “...only preliminary...” is a pejorative characterization of Goodman’s work; from her point of view it was a finished, peer-reviewed publication that reported laboratory observations. It was no more nor less “preliminary” than any other published scientific report. The real problem with this work, from Repacholi’s perspective, is that it pointed in a direction opposite to his client’s interests.

The phrase “needs confirmation” is biased. As will shortly be clear from other parts of his testimony, it means that any report whose implications are adverse to his client must be replicated exactly before the report can be taken seriously. One difficulty with this viewpoint is that almost no published study is ever replicated exactly. The desire to do so hardly constitutes a basis, for example, to solicit funds for research from NIH, where the emphasis in securing such support is on novelty, not on aping the results of others. Published studies are not replicated because usually no one is interested in paying for duplicative studies.

Repacholi is hypocritical because he applies a “replication” standard only to reports that are adverse to his client’s interests. If Dr. X reports that EMFs don’t produce a particular biological effect then Repacholi applies no replication criterion, presumably because he sees “no effect” as the “right” result. If Dr. X reports a positive result, Repacholi raises the bar for acceptance by requiring “confirmation.” Thus he has two standards for scientific acceptability, depending on whether or not he likes the results.

Should a decision regarding whether EMFs are health risks be made on the basis of an overall evaluation of the cumulative, credible evidence, or should the rule be that a nexus between each individual report and the overall conclusion must be established in order to rationalize a conclusion of risk? It is obviously impossible to satisfy the latter criterion, and thus an insistence on its applicability amounts to prevention of any rationalization of health risks. It is possible to imagine a society in which health risks are not recognized, except in particularly egregious cases (living next to a dynamite factory, working in an asbestos mine, smoking cigarettes, for example). It could be argued that society is better off, overall, if the bar is set so high. The point is, however, that whether that point of view is accepted or not is a societal decision, and is not properly one within the purview of a single, arrogant scientist such as Repacholi. He has no authority whatever to address that issue in the context of testifying as an expert for the power company.
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COMMENT 10: Calcium ions can also be released from intracellular stores, and as a consequence, produce diverse cellular changes. Repacholi seems ignorant of the phenomenon because he interprets the literature as if transmembrane ion flow were the only pertinent source of calcium ions.
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COMMENT 11: Whether the difference has been “satisfactorily explained” is quite subjective, and the implicit assertion that such an explanation is needed in the context of this case is misleading. Finally, the paragraph implies a false dichotomy; both experiments showed that EMFs affected calcium movement. There is no inconsistency because the experimental conditions differed between the two studies.
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COMMENT 12: The argument here was created by Edwin Carstensen, an engineer from the University of Rochester, during his testimony on behalf of the power industry in a forum in New York in 1975; the argument is foolish for 2 reasons. First, the calculation (like essentially all such EMF calculations) was completely arbitrary. By assuming different values for tissue constants and tissue geometry (such assumptions are absolutely necessary to perform the calculations) it is possible to produce results that are equally justifiable as the proffered results, but that differ drastically in the numerical values that they produce. Thus, the calculations have no probative value.

Second, drawing parallels between studies done at widely divergent frequencies for the purposes of establishing “the same tissue gradient” makes no sense because it is expected that physical processes will vary as a function of EMF frequency. Carstensen’s arguments were rejected in New York. Yet Repacholi introduces them as if they are meaningful, relevant, and uncontradicted.
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COMMENT 13: The statements are purely gratuitous. Such terms as “unusual,” “not established,” and “do not support” do not characterize the work, but rather the dishonest approach to the literature followed by Repacholi. The real problem here is that the studies are used by people Repacholi regards as enemies to jeopardize his client’s interests.
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COMMENT 14: The work of Albert, Merritt, and Graves was rigged by the commercial interests that paid for the work; its purpose was to put the work of Adey and Blackman into issue so that ethically compromised witnesses such as Repacholi could denigrate the work as “scientifically unsatisfactory.”

The term “Cheshire cat” was coined by Graves to explain all EMF bioeffects who, contrary to what Repacholi says, did not limit its import to the calcium studies.
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COMMENT 15: The work is quite irrelevant. In the rabbit hole that Repacholi jumped in, evidence that someone looked for a phenomenon and didn’t find it is evidence against the existence of the phenomenon, notwithstanding the fact that someone else did find it.
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COMMENT 16: This is another example of Repacholi’s selective reporting. In other studies, the same authors reported effects of EMFs on calcium movement.
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COMMENT 17: The work by Blackwell and Reed was controlled by the power industry, which invariably indicates that the work was rigged. It should be noted that industry-supported work is not simply incompetent (it almost always finds no effects, and anybody can fail to find something). The work is far worse—it is actively misleading. It is, in effect, a form of advertising that is created by the industry to deflect attention from the serious health risks produced by the way the industry designs and builds powerlines.
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COMMENT 18: As with essentially every “conclusion” Repacholi reaches, it is unrelated to the state of the scientific literature, but rather derives from his mission which is to exonerate the power industry.
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COMMENT 19: The work of Adey and Byus is interesting for both historical and scientific reasons, but it is largely irrelevant in a powerline hearing. It would be relevant if it were legally required that a claim powerline EMFs constituted health risks must be supported by a showing of the cellular mechanism that mediates the process. There is no such requirement. Repacholi’s testimony is intended solely to create collateral issues that present an insurmountable obstacle to the recognition of powerline health risks.

Both Bailey and Boutwell are industry hacks; they work for the same employer as does Repacholi.
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COMMENT 20: Of course the results weren’t supported by Morris and Phillips; they worked for the power industry. In the late 1970s and early 1980s Phillips was in charge of a veritable data-fabrication factory at the Battelle Pacific Northwest Laboratories; the product was false and misleading information regarding the health risks of powerline EMFs. It is impossible to pinpoint his budgets during those years because almost everything about his work was secret except for selected releases of data that suited the interests of the industry. I estimate that he controlled or at least influenced $100–300 million in research funds. Even as the work was being produced it was apparent to unbiased observers that the work was worthless. Today (December, 2005) it is not possible to delineate even a single published report from Phillips’ laboratory that provided useful or worthwhile information about the biological effects of EMFs. There is no report, not even one, regarding which I can tell my students, “Here, read this, it says something true and useful about understanding the biology of EMFs.” The reason is clear; none of the work was ever intended to do so. Rather, it was intended to obfuscate the issue in the eye of the public. All this was surely known by Repacholi.
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COMMENT 21: Repacholi constantly sets up inappropriate contrasts, irrelevant criteria, and insurmountable hurdles in the path of any realistic attempt to evaluate the health risks due to powerline EMFs. These strategies are folded into virtually every paragraph he writes, and it is easy for an honest but naïve reader to miss the point that the testimony is corrupt by virtue of its very structure, as well as because of the distortion of the facts discussed in the testimony.
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COMMENT 22: All of the organizations discussed by Repacholi are dominated or controlled by the EMF-producing industries. Not surprisingly, the organizations see no problems with exposure of the public to EMFs. Almost invariably, the rules propounded by these organizations were designed to avoid obvious or acute effects (cooking of tissue, electrical shocks). No other effects are recognized by these organizations, and hence no other protections are built into the standards that they adopted.

In some instances the adopted standards call for levels even below those that produce cooking or electrical shocks; in these cases, it had already been determined that the lower levels were consistent with the normal patterns of business in the industry. That is, if level x is sufficient to avoid electrical shocks but in the normal course of business the public is not exposed to levels higher than y, where y is less than x, then it’s prudent to set the standard at y, rather than x. Such a strategy creates the impression of solicitude for the public but costs the industry nothing. These simple considerations are behind the standards set by the organizations discussed by Repacholi. His testimony is therefore fundamentally misleading because he obscures the underlying bias.

His testimony is also misleading for another reason. He presents the process of evaluating scientific evidence for the purpose of determining the extent of risk as if it were a scientific process, whereas it is actually a societal process that involves human judgment, and human values. The values incorporated into the standards of the organizations he discusses are strictly those of the industry; the consumer, the victim, and the general public all have no significant voice in the standards-setting process.
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COMMENT 23: “Established scientific literature,” “preliminary or unconfirmed data,” “unproven hypotheses,” and “higher degree of confidence” are subjective criteria. In this testimony, and throughout his career, Repacholi employs such language as a code to indicate what reports he will accept or reject based on the interests of his clients.

Note the misleading metaphor he implicitly adopts for science—that science can prove hypotheses. Knowledge that will never need to be revised (“change significantly with further research”) cannot occur in biology.
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COMMENT 24: Repacholi is perhaps the leading expert in the world who guides governmental agencies in setting health standards to protect against EMF health risks. From his bully pulpit at the World Health Organization he writes and speaks with the Kafkaesque perspective embodied in this paragraph, but yet is essentially immune from criticism, control, or accountability. He is like King Canute, except that the tide of truth has obeyed his command and ceased to roll in.
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COMMENT 25: The purposes for which in vitro (or any other) scientific studies are conducted depend on the aims and goals of the investigators. Repacholi is particularly afraid of in vitro studies because they are relatively inexpensive and easy to perform, and thus they have a serious potential to create problems for his clients. For this reason, he would like the judge to see in vitro studies as preliminary, unreliable, unrelated to evaluating risk, and of generally dubious value. Repacholi’s ipse dixit often prevails, with the result that in vitro studies are under-evaluated by the judge, or excluded altogether from consideration.
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COMMENT 26: Repacholi seems to believe that the proper way to deal with toxic agents in the environment is for superior individuals (scientists) to make rules regarding what levels of the agent are “safe” for the general public. He ignores the fact that each such rule is value-laden, and that his testimony is based principally on his personal values. Value-laden rules may be credible when they are promulgated by democratically constituted authority, but they have no validity when they arise from the ipse dixit of private individuals.

Repacholi never considers replacing or supplementing his autocratic system with a system of honest science in which the best available knowledge is provided to the people, who then make their own decisions regarding how much and what kind of risk they will accept.

For Repacholi to argue that adequate safety factors are needed is like the fox insisting that the guard around the henhouse be increased. His testimony in this case, and his actions throughout his career amply illustrate that he has never advocated a meaningful safety factor, or even identified a non-trivial biological endpoint that such a factor could be designed to obviate. Repacholi, in short, is a hypocrite.
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COMMENT 27: There is no chronic biological effect caused in the bodies of human beings exposed to powerlines that wouldn’t be presumed to be a hazard to human health. With the exception of those who work for power companies, I have never heard anyone argue otherwise.

The quantum levels of EMF ELF frequencies are what they are, smaller than some but larger than others; to refer to them generically as “negligibly small” is vacuous. It is self-contradictory for Repacholi to caution against dismissing the possibility of effects due to powerline fields since that is exactly what he is urging on the court in this testimony.

The paragraph is characteristic of Repacholi’s strategy of mixing physics-type statements (“Energy is absorbed by...”) with purely subjective terms (“considered a hazard,” “negligibly small,” “negligible physical perturbation”). It’s as if he expects the reader to psychologically project the certainty of physics-type statements onto his personal judgments regarding EMF health risks.
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COMMENT 28: It is a contradiction to claim than an “effect” is not “measurable,” because one would never know that it had occurred unless it were observed and measured.

The second sentence is a tautology; to be “aware” is to sense or perceive something.
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COMMENT 29: The difficulty in defining “health hazard” arises because value judgments (which are not based on scientific analysis) are intimately involved in whatever language is adopted.
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COMMENT 30: Repacholi is like a magician who talks to his audience to maintain their attention while he manipulates an object that is in plain view but not actually seen by the audience because their attention has been diverted. The goal of understanding how effects caused by exposure to electromagnetic fields are brought about, however laudable, is irrelevant in a legal proceeding to determine whether such fields constitute health risks. If one is distracted into believing that recognition of the existence of health risks is somehow tied to the need to understand the physical processes that mediate the risk, then recognition of the risk can be deferred endlessly.
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COMMENT 31: This double-talk is similar to that one can see in the statements Repacholi makes today on behalf of the World Health Organization concerning the health risks of electromagnetic fields. His pattern of deceptive speech was perfected almost 15 years ago in this testimony.

A normal range of a biological parameter is generally defined to be that found in subjects who display no overt clinical disease. Normal range is a definition, not an implicit assertion regarding an interval within which companies are permitted by the law to involuntarily induce changes in individual subjects under an irrebuttable assumption that the changes are “safe.” There is no biologically-based rationale to assert that a change in a parameter in a subject must be safe as long as the endpoint achieved is within the range for the population, which is exactly what Repacholi asserts here.

The brutal notion advanced here by Repacholi originated in the work of Solomon Michaelson, a veterinarian at the University of Rochester who experimented with the effects of electromagnetic fields on dogs (see Comment 8). Michaelson’s experimental model consisted of inserting a rectal thermometer in dogs and measuring core temperature as the animal was exposed to microwaves. The typical observation was that the body temperature would begin to rise, but would return to normal when the microwave exposure was terminated. If the exposure was maintained long enough, however, a point could be reached where the body temperature continued to rise even when the microwaves were terminated, resulting very quickly in the death of the dog. Michaelson worked to identify the critical temperature beyond which death ensued. His notion was that, for shorter durations of exposure the body could “handle” the microwaves because it could “adapt” to them. The industry philosophy that evolved from these experiments was that reversible changes were evidence of a “normal” response of the body and therefore could not be considered to be a hazard.

The next step in the pro-corporate reasoning process was to assert that if something wasn’t a hazard the first time it occurred, it couldn’t be a hazard the second or succeeding times it occurred. Since chronic exposure can be considered to be a continuous series of individual exposures, like a modern-day Zeno, the conclusion was reached that the exposure must be safe.

The point to be recognized is that Repacholi is not wrong because of science-based reasoning, he is wrong because he passed off value-based judgments as if they were science-based. A democratically-based regulatory authority might decide that society would best be served by a rule that equates short-term reversibility of a biological effect with “safety.” But Repacholi is no democratically constituted authority, and he therefore has no right to arrogate this decisional authority onto himself.

Any decision by a properly constituted authority to adopt the Michaelson model must occur in the context of full disclosure of all relevant information, and an honest attempt to understand the limits and dimensions of the physical effects produced by EMFs. The public cannot rationally agree to a policy if they are lied to about the underlying evidence, or if that evidence is hidden. Whenever Repacholi has had the opportunity to use his position of dominance at the World Health Organization to press for honest, open research on the part of the power companies and cell-telephone companies, he has taken the opposite tack, namely he has lauded the efforts of the corporations and treated the work that they control as if it were real science.
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COMMENT 32: The analogy is seriously misleading because it obscures and commingles the issues of voluntariness, the pre-existing health conditions of the subject, and the benefit for whom the activity is performed. A more apt model is that of an investigator who secretly places a potentially toxic agent in the food consumed by an old man with the ultimate aim of developing a product that might improve corporate profitability.
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COMMENT 33: The use of vaporous language and the passive voice cannot disguise Repacholi’s notion that the technologically elite are fitted by nature to tell other human beings how they ought to live and what risks they ought to endure.
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COMMENT 34: The proposed rules are capricious; they serve only to validate the status quo, which is the situation that EMF exposure is considered to be perfectly safe absent immediate, egregious, clear, and certain evidence to the contrary.

  • (a) is an axiom, not an observation.
  • (b) is wrong because it is unbiological. Effects are rarely specific, as is well shown by the plethora of diseases associated with cigarette smoking.
  • (c) is a characterization of a linear disease process, but nothing indicates that EMF-induced effects are linear. The only causal requirement is that the “dose” must actually produce the “effect.” There is no rational necessity for higher levels of the “dose” to produce greater (or less) amounts of the “effect.”
  • (d) is not a reasonable requirement (unless it is precisely defined) because “consistency,” like the beauty of a rose, is in the eye of its beholder.
  • (e) is a fatuous requirement because “exclusion” is never possible as regards biological systems. The best one can do is to offer reasons why one alternative should be regarded as a better characterization of the truth than another.
  • (f) is simply foolish, like expecting that an escaped horse will rematerialize inside the barn if only someone closed the barn door.
  • (g) What “consistency” is can be agreed upon, but when viewed as an objective concept it is insufferably vague and imprecise.

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COMMENT 35: Although these factors relate to empirical observations, the meaning ascribable to them is largely subjective. In this testimony and throughout his career, Repacholi invested them with the meaning preferred by his employers while misleading the public into believing that the meaning is objectively based.
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COMMENT 36: At high levels, EMFs cook tissue and cause electrical shocks. It doesn’t take a genius to realize that such effects are adverse, or to document the actual EMF levels at which the effects occur. It would be about as difficult to generate controversy concerning the “adversity” of these effects as it would be to plausibly deny the existence of gravity. As Repacholi well knows, the real health problems exist at sub-thermal EMF levels where arguments can be made that no effects exist (for the reason that the effects are not utterly obvious, as with cooking tissue).

It is amazing that the term “safety factor” doesn’t stick in Repacholi’s throat like a chicken bone, because he has opposed and obfuscated that concept in this testimony, and subsequently, throughout his career.
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COMMENT 37: No proper foundation was laid. What is IRPA/INIRC? Who appointed them? What are their values? Even more fundamentally, is the question of health risks from powerline or microwave EMFs a question that should be decided solely by technical experts? The fact is that the question involves issues of science and justice, and therefore cannot properly be decided only by technical experts.
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COMMENT 38: Repacholi neglects to point out that the criterion of 10 mA/m2 is based solely on the phenomenon of electrical shock and tissue heating. In other words, to assert the applicability of that current density to the problem of safety of EMFs is equivalent to an assertion that the only health risks that need to be considered involve tissue heating and electrical shock.
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COMMENT 39: The testimony is misleading. The only reason pro-industry groups favor a current density of 10 mA/m2 is that it is consistent with present business practices. The choice has nothing whatever to do with good-faith scientific evidence.
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COMMENT 40: This argument has a black historical setting. It was originated by Herman Schwan, who worked in Nazi Germany during World War II and was then brought to the United States in 1949 by the United States Department of Defense because his expertise was deemed essential to the security of this country. He was an expert in the biological effects of EMFs, and that issue had arisen here within the context of the safety and use of electronic communications and radar systems. Schwan concocted the following argument. Electric fields produced by radar and electronic communications systems are in the range of 1-20 V/m, rarely higher. However, there are electric fields inside the body that are 106 V/m, for example, the electric field that exists across the membrane of any cell. Since the electric fields to which a subject is ordinary exposed is so much smaller than the fields that already exist in the body, the exogenous fields can’t possibly be harmful.

In this paragraph, Repacholi makes essentially the same argument, using the language of current density rather than electric fields. The argument was nonsensical biology when it was first made by Schwan, and it remains nonsensical biology when paraphrased by Repacholi.
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COMMENT 41: It is the remarkable oiliness of Repacholi’s language that makes him so useful to companies and such an obstacle to those who would really like to understand the truth. In (a), for example, to say that it is “difficult to extrapolate” animal studies really says nothing new, as if Repacholi had discovered hot water. Similarly, what constitutes “unnecessary” exposure or “strong” electric fields are important things to establish in the context of the testimony. When mentioned in the abstract, as Repacholi does, these concepts have no meaning.

It’s the same story in (b). What does he mean by “adverse” or “normally encountered,” or “not...established?” He never says.

Paragraph (c) is a red herring because no company would create a situation in which its customers constantly experience shock discharges. This issue is irrelevant in the context of the extent of human disease caused by chronic exposure to EMFs.

Paragraph (d) returns to the misleading structure of the language employed in the first two paragraphs. The only experts in this trial who made the suggestion that the data relating EMFs to causing cancer in children should be “dismissed” were Repacholi and the others who were hired by the power companies. They told the court they had considered the data and that it did not rise to the level of requiring any remedial action. In other words, the data could be “dismissed.”
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COMMENT 42: True, but Repacholi’l;s interpretation of this fact (that the changes aren’t real, because real changes must be consistent) is incorrect. For toxic agents administered chronically at low levels, the effects must be inconsistent (if they were consistent then the levels would be “high,” by definition).

In making this argument, it’s hard to know whether Repacholi is just stupid concerning processes in biological systems, or intentionally misleading. Perhaps he really doesn’t know any better (see paragraph 19: “I am not a researcher”). In this view he is like the guard at a brick factory. At the end of each day a worker left the factory pushing a wheelbarrow full of straw, and the guard always stopped him and poked through the straw trying to determine whether he was stealing bricks. It turned out he was stealing wheelbarrows. Repacholi completely misses the fact that most honest investigators who study EMF effects find them. The message, therefore, is that the effects exist (and thus have health implications). The inconsistency of the effects does not argue against their existence, but rather gives insight into their causal mechanisms.
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COMMENT 43: The cited blue-ribbon committees were controlled by the power industry. It is not reasonable to expect that they would give much consideration to the interests of exposed subjects.

The calculation of current densities is meaningless, at least with regard to setting safety standards. If an industry proponent wants the number to be low, he simply makes assumptions (always necessary for any calculation) that lead to the favored conclusion. Conversely, an industry opponent makes different assumptions. The salient fact is that either set of assumptions is equally defensible (or indefensible).
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COMMENT 44: All of the studies showed significant adverse effects on growth and development, even though the authors didn’t know it and I had to point it out to them (Marino AA. Different outcomes in biological experiments involving weak EMFs: Is chaos a possible explanation? Am J Physiol 1995;268:R1013–R1018).

More generally, it makes no sense to rely on the work of Phillips and his employees because their work was rigged.
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COMMENT 45: The quoted studies show the length to which the power industry will go to produce rigged scientific data. No one in the world takes a back seat to Phillips regarding the quantity and quality of the experiments that he produced that falsely implied EMFs were safe. Also high in the list of investigators who produced false science was Bonnell, who for years was the chief scientist of the British electrical power system (the CEGB). Bonnell’s work is a textbook example of how to design laboratory and epidemiological studies that are essentially guaranteed to not find causal relationships between EMFs and biological endpoints.
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COMMENT 46: Almost every species of misleading connotation can be found in this simple paragraph. We can see vague language, drawing conclusions from self-serving studies, conceptual ambiguity, inapplicable criteria, and outright lies.
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COMMENT 47: Repacholi often cites the WHO 1984 report approvingly. What he neglects to reveal to the court is that the first paragraph in the report says, “This report contains the collective views of an international group of experts and does not necessarily represent the decisions or the stated policy of the World Health Organization, the United Nations Environmental Health Program, or the International Radiation Protection Association.”

Who exactly were the “international group of experts?” It consisted of a committee chaired by Repacholi, consisting of Bonnell from the Central Electricity Generating Board in England, Vosnjakovic, a government bureaucrat from the Netherlands, Cabanes, the representative of the French national electricity company, Gandolfo who represented the Italian power industry, Knave from Sweden, Kupfer from Germany, Phillips and Sheppard who represented the American power industry, and Portela who represented the Argentinian power industry. Not one member of the committee could be considered to be an unbiased expert.
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COMMENT 48: Industry-controlled studies of its own employees are the worst form of industry propaganda concerning EMFs. Not only do the companies not intend to tell the truth, or even to look for the truth, but also the employees are enormously compromised from a psychological viewpoint. I saw this when I spoke with employees of at the American power industry’s high-voltage test facility in Pittsfield, Massachusetts. The workers there were exposed to EMFs from a test powerline operating at 1 million volts, and many of them complained about joint pain that they had experienced after the line had been energized. They observed that the onset of the pain coincided with when the line had been energized but they didn’t want to consider the possibility of a causal relationship. For one thing, the employees didn’t think their companies would do anything that might possibly endanger their help. More profoundly, even if it turned out to be the case that the powerline EMFs had caused the joint pain, the workers enjoyed their jobs so much they were prepared to accept the joint pain if it were entailed by the job. So the workers did not report their symptoms to their employer. Their psychological status and value system therefore became an important determining factor in the so-called “scientific” judgment whether powerline EMFs are a health risk.

If any useful knowledge regarding EMF-induced health problems is to be obtained from occupationally-exposed workers, the study must be carefully designed to take into account the workers’ attitudes about the job and its importance in providing their livelihood. This, the power industry has never done.
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COMMENT 49: Repacholi cites the WHO 1987 committee report as if it were an honest and unbiased evaluation. However, that was not the case.

The committee began in the usual way. The power industries in the various countries sent their representatives to WHO. Also, as usual, Repacholi was the power behind the throne; his official title was “rapporteur,” which meant that he was the person who kept the record of what was said during committee discussions, and who wrote the drafts and the final committee report.

There was a wide difference of opinion between the representatives from the West and the Soviet Union regarding the health effects of EMFs. The industry representatives from the West didn’t believe such effects existed, whereas EMF-induced health effects were quite well accepted by the industry in the Soviet Union, where various hygienic rules had been adopted to mitigate the effects.

The Soviet representatives were from the Marzeev Research Institute in Kiev, which was probably the principal source of published Soviet reports concerning the health implications of powerline EMFs. Professor Shandala, from the Marzeev Research Institute was actually the co-chairman of the committee (along with a bureaucrat from the French Atomic Energy Institute).

Predictably, the committee members from the West and the Soviet Union voiced diametrically opposite opinions in the committee discussion. That proved no problem for Repacholi. He simply wrote the report the way the Western power industry wanted it written, and issued it under the auspices of the WHO.

Careful perusal of the WHO 1987 report will reveal that it says only that the Soviet investigators were on the initial committee. The report does not actually say that the Soviet investigators participated in the drafting of the report, or endorsed what was written, although the report is pregnant with that implication.

In fact, Shandala did not agree, as can easily be seen by reading the chapter he wrote at about the same time he was listed as taking part in the WHO committee (see The Biological Effects of Power-Frequency Electric Fields in the Environment, Shandala, Yu.V. and Dumanskiy, Y. in Modern Bioelectricity, Andrew Marino, Ed., Marcel Dekker, 1988).
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COMMENT 50: The WHO 1989 report follows the same low standard for honesty and scholarship as the WHO reports of 1984 and 1987. WHO 1989 may be the worst because Repacholi arranged for the two chapters that deal with EMFs to be written by Sol Michaelson and Rudolph Hauf, both of whom had a long history of acting as shills for the power industry.

I first contacted Hauf in the mid-1970s after I learned that he had written his dissertation on effects due to powerline EMFs. Even allowing for the fact that I did not read German well, his dissertation made no sense to me. He had performed a series of experiments on human volunteers exposed to power-frequency electric fields, but the data pertinent to his conclusion that the fields were biologically unimportant was not analyzed statistically. I wrote and asked him for a copy of his laboratory data, and told him that I’d be willing to undertake a statistical analysis to see if it supported his conclusion. He replied, “We are capable of undertaking such an analysis,” but he did not perform the analysis or provide the data.

In the WHO 1989 report, he dismissed the possibility that powerline EMFs were health hazards. He said that the reported effects “can easily be explained by secondary effects which are not field-specific.” He said that the results of animal experiments cannot be directly extrapolated to humans. He dismissed the Russian reports dealing with effects of fields on the nervous and cardiovascular system as being merely “transient functional disorders,” and not “organic...permanent injuries.” With remarkable chutzpah, he called for the use of better statistics in evaluating EMF studies.

He said, “Adverse effects on the nervous system are of a functional and general nature. Since EEG changes are not associated with any symptomatology, their occurrence is not explained, and they are only of theoretical importance.” He said that the effects of fields on EEGs, cardiovascular measures, blood changes, changes in reaction time, serum triglyceride levels, and stress were all biologically unimportant. Hauf’s analyses deserve only contempt.

Hauf, Michaelson, and Repacholi (who selected them to serve on the WHO 1989 committee) are better suited to running a concentration camp than they are to giving the world advice regarding the health hazards of EMFs.
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COMMENT 51: This paragraph displays Repacholi’s moral and intellectual shortcomings and also highlights a deep flaw in the English common-law system.

Commonly, the expert is asked to state his conclusion but is not asked to explain the basis for the conclusion, by which I mean the evidence analyzed and the method by which the conclusion is drawn from the evidence. In this paragraph, Repacholi explains the way he thinks the world is, and he expects to be believed because he has a Ph.D. Alas, that’s more or less what happened in this case.
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COMMENT 52: It is standard power-industry strategy to couple a discussion of health-related problems due to electric shocks with a discussion of health-related problems due to EMFs. The former are obvious, occur by means of well understood mechanisms, and are capable of being mitigated by obvious, common-sense steps. The obvious power-industry subtext is, “As we have eliminated the shock problem, so also have we eliminated the problem with EMFs: don’t worry.”

The industry strategy has a second salutary effect, from their point of view; it takes up space and time, as in this testimony, making it more difficult for a well-meaning judge to isolate the true problem presented in the case.
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COMMENT 53: Paragraphs 126–129 capture the engineering mentality of the power industry regarding the health-risk issue.

According to their view, induced currents are a problem at a precise level for adults, and at a second precise level for children. Everything bad that can happen is captured by those two levels which, in turn, are caused by a field of 5 kV/m. in other words, if the electric field is less than 5 kV/m, everybody is safe. So, engineers know exactly how to build the powerlines that they will be safe—the pertinent design criteria is that fields of more than 5 kV/m do not occur in the general environment.

It is a myth, of course, that the world can be correctly summarized in that fashion, but it is a useful myth to the industry because it entails what the engineer desires most a design criterion. Repacholi’s testimony is simply an extension of this myth. It is convenient for him to maintain the story that 5 kV/m is safe with regard to chronic exposure to electric fields, because that level is already a design criterion for the industry.
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COMMENT 54: Paragraphs 130-148 deal in a crude fashion with a crude problem. No one enjoys receiving electrical shocks near powerlines, or being exposed to intense fields that cause tingling or piloerection. Employees of power companies such as linemen accept these discomforts because it is a condition of their employment. Most people, however, resent having these discomforts involuntarily thrust upon them, and powerlines are therefore designed so that their fields do not normally produce these acute effects. From Repacholi’s perspective, the lowest field that doesn’t produce them is “safe.” That is untrue, and surely Repacholi knows that it is untrue.

The safety levels for magnetic fields were defined by the power industries in the various countries by means of a similar process; these levels are no more “safe” than the levels cited by Repacholi for the electric field.

The salient point is that the power industry cares primarily for itself, not the public, and Repacholi cares primarily for the power industry.
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COMMENT 55: Paragraphs 149–189 are comments by Repacholi regarding the Environmental Impact Statement (EIS) submitted by his employer, the Australian power company. The EIS was designed to impress the court with the company’s efforts to insure that the powerline would be completely safe, or at least as safe as conscientious and caring human beings could build a powerline. The EIS said to the court, “Your honor, we did the best possible job. You can trust us.” Not surprisingly, Repacholi finds that the power company did an exemplary job of analyzing the situation and controlling for any potential problems. Repacholi says to the court, in effect, “Your honor, these guys ought to be commended for the fine job that they did.”

In truth, the EIS is a self-serving document mere puffery, like the claims of a used-car salesman. By enthusiastically embracing the EIS, Repacholi again shows us that he cares primarily for just himself and his clients.

Repacholi’s method of analysis shows us that he has an inferior mind. In these paragraphs, he tells a myth about events that supposedly took place, and then he gives an interpretation of these events he attaches meaning to them. There is no independent evidence that the events took place, and all of the meanings he attaches are entirely subjective. Nowhere does he consider opposite points of view, alternative explanations, or the values or opinions of others. At no time does he enter into a dialogue that might allow delineation of the best truth that could emerge from what are admittedly complex and uncertain situations and conditions. Repacholi is a man with many opinions, but his writings are devoid of analysis. He is a rhetorician, whose skill is in telling myths to convince judges and the public.
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COMMENT 56: The structure of this paragraph is misleading. The first two sentences are true in the sense that they properly characterize what I said, and also in the sense that they properly characterize the physics of powerlines (see Hart FX and Marino AA: Energy flux along high voltage transmission lines. IEEE Trans. Biomed. Eng. BME-24: 493-495, 1977; Hart FX and Marino AA: Public health aspects of the energy flux of high-voltage powerlines. Innov. Tech. Bio. Med. (French) 5:636-640, 1984). In the balance of the paragraph Repacholi seems to be correcting my testimony, but that is not actually the case. He simply adds one more wearying paragraph of drivel that someone who honestly wants to evaluate the basic issues must wade through. Repacholi’s strategy baffle them with bullshit would be funny except that he uses the bully-pulpit of the WHO to mislead large numbers of people.
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COMMENT 57: The power company proposes to chronically expose the family living in the dwelling located 180 meters from the powerline to an electric field of 80 V/m and an electric field of 1.7 mG. If the fields had no health consequences for the family, there would be no health basis for requiring the company to build the line in such a way that it did not produce fields at the house. The issue, therefore, is whether chronic exposure to those fields entails any additional risk for disease for the family, compared with their risk for disease if they weren't forced to live in the powerline fields.

What evidence should be considered in making the judgment regarding the existence of the risks? In effect, Repacholi says that if we want to know about health risks of 80 V/m and 1.7 mG, then those are the fields we should study. But why does he say that? How does he respond to the argument that stronger fields are relevant because, in laboratory, studies, exposure durations are necessarily shorter than a human lifetime? Repacholi fails to address this issue or to justify his point of view.

Suppose that we ignored the fact that the EIS quoted almost exclusively from rigged industry research. Instead, assume that the 2 reviews and 6 articles were honest and complete, and that they did not disclose any health hazard. Are we then to consider that the company had fulfilled its responsibility to the family? In other words, is it true, as Repacholi implies, that there is no affirmative duty on the part of the power company to insure that innocent members of the public are not subjected to increased health risks? It seems to me that since the company cannot exclude the possibility that the family would be at some risk, the company has a moral or legal obligation to purchase the property at fair market value, as was done by British Columbia Hydro when they built a powerline on Vancouver Island.
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COMMENT 58: The analysis is entirely self-referential which is Repacholi’s characteristic style. The EIS is not “exhaustive,” but it is “reasonable,” and “appropriate.” How do we know? Because he says so.
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COMMENT 59: One problem with adopting the philosophy that involuntary human experimentation is acceptable, as Repacholi does, is that it becomes a self-fulfilling principle. He begins with the conclusion that there are no EMF-induced effects, from which he draws the inference that carefully parsing all of the studies is unimportant. If it were his children who were being experimented upon, his perspective would likely be quite different.
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COMMENT 60: According to Repacholi, WHO has analyzed the relevant literature and reached correct conclusions. It is therefore unnecessary for others to cover the same ground, and in the interests of efficiency everyone should believe what WHO says. That is apparently the way he thinks science works. Repacholi doesn’t reveal that he rigged the WHO committees and drafted their reports.

Lawyers from Tom Watson’s law firm were present at the trial of this case, and Watson’s fingerprints are all over the case that Repacholi argued. The high-frequency/low-frequency dichotomy is a good example. It was Watson who perfected the courtroom argument that EMF studies involving biological effects need to be stratified into “low frequency” and “high frequency.” In this approach, high-frequency studies are not applicable to powerline cases, and low-frequency studies are not applicable to cell-telephone cases. Why? Because Tom Watson has mouthpieces like Repacholi who is willing to boldly assert that principle in a manner completely devoid of analysis.
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COMMENT 61: This is another version of the Watson high-frequency/low-frequency argument.

The argument was originally made in the smoking-cancer cases. The defendant cigarette company argued that epidemiological evidence of the link between smoking and cancer should be restricted to studies that involved the brand of cigarettes used by the plaintiff. The argument was rejected by the courts, but from the point of view of a defense attorney representing a toxic-tortfeasor it is a reasonable strategy to attempt to implement. If successful, it has the effect of greatly limiting the amount of evidence that can be adduced by the opposition. Watson has employed this argument in every case of which I am aware that he or his firm has litigated, often successfully.

Optical fibers have not been used by me or any of hundreds of other investigators who have studied the effects of EMFs on brain waves in animals or human beings. Repacholi’s implication to the contrary simply manifests his ignorance regarding how such studies are performed. As Repacholi told us (paragraph 19 above), he is no researcher; he further confirms that limitation in this paragraph.
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COMMENT 62: Only a pedestrian mind such as Repacholi’s would regard negative evidence as probative regarding the meaning of an entirely different experiment. The work of Bankoske and Silney does not negate or materially lessen the implication of Blanchi’s work.

Bankoske’s work was done pursuant to a contract with the Electric Power Research Institute. The terms of their research contracts provided that the Institute owned all the data, and its policy was to authorize publication of only the portions that were favorable to their interests. BankoskeRĺ17;s work, therefore, did not merit being relied upon for any purpose.

I knew Lott well. Repacholi’s reference to his work is quite bastardized. Lott was one of the first investigators to report the effects of EMFs on the EEG. However, not every condition in his experiments resulted in the detection of an effect; Repacholi seizes on this fact to cite Lott as if his work supported Repacholi’s clients—the truth is just the opposite.
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COMMENT 63: The study is characterized as “old,” which Repacholi clearly intends for the court to understand in a pejorative sense. The problem with the study, however, is not its age, but the fact that its results are antagonistic to the interests of Repacholi’s clients. He welcomed even older studies when the results were more to his liking. For example Boutwell (1964), Heubner (1969), Roe (1959).

Repacholi says that the leads were “interfered with by the electric field.” He has no evidence that was the case, he simply asserts it was so. Repacholi learned this trick from Herman Schwan.

Fifteen years earlier, I had been assisting in the cross-examination of Herman Schwan in a case in New York. We presented him with paper after paper that showed biological effects of EMFs, all of which he had previously testified were impossible, based on his understanding of the biophysical principles of EMFs. That being the case, from his perspective, there had to be some defect in the apparent positive results reported in the studies that we presented to him. What were the defects? Schwan said that Wever, who worked in Germany, hid data that showed there were really no effects. Schwan said that Southern, whose research had been published in Science, had used faulty statistics. This pattern continued for several hours; according to Schwan, every report of a positive effect was scientifically invalid for a specific, enumeratable reason, none of which Schwan could actually substantiate. Then, we confronted Schwan with a series of reports dealing with experiments performed at Hazelton Laboratories for the United States Navy, all of which were completely negative. The work was so bad that even the Navy hadn’t used it in its publicity in support of a large antenna that the Navy was then in the process of building. Schwan testified, under oath, that the reports were good science, and that he accepted their results. We asked him if he actually read the reports and he said, “No. Once I realized that the reports were negative I had no further interest in digging into the material.”

For Schwan, and for Repacholi, reality is nothing more than what they desire.

Optical fibers were never seriously used in connection with EMF EEG studies; Repacholi apparently heard something to the contrary, somewhere, and decided that the judge would never recognize that the comment was pure bullshit.

Now, 15 years after Lott’s article there are more than 100 published reports involving the effects of EMFs on EEGs, indicating that Lott was essentially correct, and that Repacholi submitted dishonest testimony to the Australian court.
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COMMENT 64: The fact that the study may have been discussed at the WHO 1987 meeting indicates only that the power industry was concerned about its implications for their interests.

I knew Friedman and Carey well; they never did an experiment in their entire lives that used “strong” fields. All their work involved earth-field-strength fields, and the consequences of the natural fluctuations in strength of such fields.

The argument here is an extreme version of Watson’s high-frequency/low-frequency argument (see Comments 60 and 61). Repacholi argues that 0-Hz studies are not applicable to the issue of the biological effects caused by 60-Hz studies. Even small children can’t believe that story.
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COMMENT 65: The notion of what constitutes an “obscure” journal has never been explicated by Repacholi, even though he has used that pejorative term many times. We know that it cannot mean only that the report was published in a language other than English, because his own references include publications in various languages other than English. We know also that “obscure” does not mean something like “difficult to find,” because his own references include reports that are available only to employees or consultants for power companies. It’s not possible to escape the conclusion that “obscure,” for Repacholi, means that the implications of the work are adverse to the interests of his clients.

Pochwatilo’s work was published in the journal Vratchebnoe delo (“Medical Affairs”) which deals with the medical implications of drugs and technologies. The article described the effects of powerline EMFs on endocrine endpoints in exposed subjects. The message of the paper was that the exposed workers were affected by the presence of the field. The work did not establish the presence of a disease state, but it was not intended to do so. For rational, unbiased people, evidence that power-frequency EMFs can affect the human endocrine system is the first step in honestly evaluating the possibility that such exposure could promote human disease. For Repacholi, in contrast, the fact that a direct link between EMF exposure and disease of the endocrine system was not reported is enough to dismiss the relevancy of the work.
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COMMENT 66: The immune system is not something where “decrease in response” equals “bad;” it is entirely possible that a decrease in a particular immune-system endpoint could equal “good.” Repacholi manifested ignorance concerning this basic property of the immune system.

Overall, Repacholi has two messages: (1) biology is simple; (2) EMFs are safe. Virtually every paragraph in his testimony is directly or indirectly linked to one of these propositions.
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COMMENT 67: Winters published several important papers that described biological effects of low-frequency fields, but not every experiment yielded a positive result. If it were the case that every experiment on every animal system, regardless of the exposure conditions, resulted in a positive effect, then the controversy regarding the effects of fields would never have arisen because it would have been clear to even the most rabid partisan that the phenomenon could not be denied. In this paragraph Repacholi resorts to a stratagem that he has employed routinely throughout his career—he simply cherry-picks individual experiments that, in isolation, appear to support his viewpoint. “Don't look at the big picture, just look at this,”t; is effectively what he says to the reader.

It is not possible to have a rational dialogue with someone who approaches science in this way. It is possible only to recognize the deep scientific invalidity of what he does, and then to move on.
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COMMENT 68: Characterizing the state of experimentation in a particular area as presenting “a confusing picture” usually says more about the ignorance or bias of the author of the assertion than it does about the area of science. Such is the case regarding Repacholi’s comment about the immune studies.

The official line of the power industry, echoed in this paragraph, is that because the literature is not absolutely clear, specific, categorical, indisputable, and certain, it is therefore “confusing.” This reasoning obfuscates the truth. When such reasoning comes from the mouth of a putative world expert on the biological effects of EMFs, both the reasoning and the expert deserve only contempt because its direct result is to induce innocent, naïve human beings to injure themselves.

It is not surprising that Ragan seemed to clear up all of the problems, or that Repacholi would rely on Ragan. Ragan’s work, done under Richard Phillips at Battelle Pacific Northwest, was funded and completely controlled by the Electric Power Research Institute. Repacholi well knew the history of the work. However, not only did Repacholi not disclose the link between it and the Electric Power Research Institute, he went further and invited Phillips and other employees of the Electric Power Research Institute to serve on WHO committees.
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COMMENT 69: Mathewson was an officer in the U.S. Navy, and his research was performed at a Navy facility. The work was intended to provide evidence regarding the safety of an antenna system that the Navy planned to build. Mathewson interpreted the results of the study to support the Navy’s goal of proving that the antenna would be safe. How he was able to do so is worth considering, because it well illustrates a rhetorical trick by which adverse data can be made to support a preferred point of view.

Mathewson analyzed the data under the assumption that any real effect would be linear. Thus, if application of an EMF produced a statistically significant change in a measured endpoint and application of a stronger EMF did not produce a correspondingly stronger change in the endpoint, then the planned interpretation of the data was that the EMF had no effect on the measured endpoint. This conclusion was to be adopted even if a statistically significant difference in the measured endpoint between the exposed and control animals were found in each of the two experiments.

We have known for many years that the biological effects of EMFs do not comport with the assumption of a linear response. Thus, the requirement that effects must do so in order to be recognized as “real,” is tantamount to a decision that effects due to EMFs will not be recognized, regardless of the data.

Mathewson’s data revealed numerous effects due to the weak fields that he applied to rats. I therefore concluded that he had shown that weak EMFs can affect rats (thereby raising the possibility that the Navy’s plans to expose human beings to the same fields might be a health risk) (Marino A.A. and Becker R.O.: Biological effects of extremely low frequency electric and magnetic fields: a review. Physiol. Chem. Phys. 9: 131-147, 1977). That was the proper interpretation of the data Mathewson published. However, Repacholi employed the rhetorical trick of equating an assumption with objective reality, and was therefore able to conclude that the results were “inconsistent” (because the effect on the endpoint didn’t double when the field doubled). “Inconsistent” was Repacholi’s code term for “didn’t really happen, folks. There's really nothing there.” In reality, there was something there.
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COMMENT 70: Cabanes worked for the French power industry; obviously, he could report only that powerline EMFs produced no biological changes.

Note the bias that is pregnant in this paragraph. Neglect, for the sake of argument, the facts that Cabanes worked for the power industry and that he did an experiment that differed from the one performed by Fisher. As Repacholi says, we have a positive report and a negative report. He implicitly assumes that the negative report trumps the positive report. How does he associate “truth” with the negative study? Like Schwan, Michaelson, Moulder, Adair, or Park, Repacholi simply intuits the truth, or perhaps hears it from the lips of God, then interprets everything that happens in the world in the light of that interpretation.

The comment concerning Grin is another instantiation of Watson’s high-frequency/low-frequency argument. As usual, the argument is simply repeated, never justified or explained.
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COMMENT 71: Repacholi again argues inconsistently. “Old” is a defect only when the study results are adverse to his client. He dismisses non-English studies for the same reason, especially Russian studies because they are almost always adverse to his clients. See Comments 63 and 65.

Sikov’s experiment differed significantly from that of Adrienko. There would be no inherent contradiction between the two studies, even if Sikov’s work were honest.

Rommerein was as deep in the power-industry’s pocket as Sikov. It takes an extraordinarily naïve individual to believe that either one would have dared publish an experimental result that could be construed by the power industry as adverse to its interests.

Benz’s work (which was done prior to studies conducted by Rommerein) is irrelevant. Following the decision by the New York State Public Service Commission (PSC) to deny certification for construction of a 765-kV powerline proposed by the Rochester Gas & Electric Corporation, the PSC ordered a research program into the potential health effects of high-voltage powerlines. The commission was nervous because Governor Carey had ordered it to retroactively approve the 765-kV powerline that had already been built by the state of New York. Thus, the inhabitants of the north country in New York were certain to be exposed to the powerline EMFs, thereby adding some urgency regarding the task of determining whether the exposure would cause cancer and other health problems. Unfortunately, the state power company that built the 765-kV powerline acquired effective control of the research program. The company had veto power over each member of the committee charged with oversight of the research program, and even more importantly, over the person charged with administering the program. They chose David Carpenter.

He came to prominence in the EMF area for the reason of his political power as head of the New York research program. He was a competent scientist in his area of expertise, but knew nothing about EMF bioeffects. Later in his career he came to recognize that environmental EMFs posed a significant health concern. However, at the time he controlled the $5 million research program, he was highly skeptical of the potential hazards of EMFs. He designed a research program that focused on “mechanisms,” which is a foolish thing to do if one is interested in determining the existence of health risks from EMFs. However, a search for “mechanisms” creates the illusion of attempting to answer the question of EMF risk but essentially guarantees that an answer will never be obtained.

Benz was one of Carpenter’s approved investigators. As with every other research project he funded, Benz’s work turned out to be irrelevant. Repacholi cites Benz simply because his study is negative. From Repacholi’s point of view, that indicates it’s good science, and good science is relevant. Repacholi routinely cites papers he hasn’t read that deal with subjects that he doesn’t understand and have a degree of relevance that he is incompetent to evaluate.
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COMMENT 72: The work of Giarola and Krueger was from a time when EMF research was honest.

In the late 1960s, the American power industry began to realize that chronic exposure to powerline EMFs might cause health problems. They awarded research contracts to a group at Johns Hopkins headed by an engineer named Kouwenhoven. The group examined linemen who worked around high-voltage powerlines and did studies with mice, but found nothing clear or obvious that, in the opinion of the industry mavens, required precautionary steps to protect health.

At the international conference on high-voltage powerlines in Paris, in 1972, the American power companies were directly challenged by Soviet engineers who delivered papers in which they described both health effects due to chronic exposure to powerline fields, and work rules designed to protect the workmen. The American engineers regarded the Soviet position as ludicrous. The Soviets were, after all, godless Communists known to have no regard for human life; why in the world would they promulgate rules to protect anybody? The American industry essentially viewed the Russian position as a plot intended to divert and weaken the American industry.

During the next several years, however, scientists from far outside the industry orbit began to report biological effects due to low-frequency EMFs. Giarola was one example. The appearance of these reports led to concern on the part of Chauncey Starr at the Electric Power Research Institute, and he secretly commissioned new studies by the research group at Johns Hopkins (headed by Dr. Donald Gann following Kouwenhoven’s exit). In May, 1975, Gann’s group performed experiments on baboons in which they found adverse effects due to powerline EMFs. In June, Chauncey Starr canceled the contract. Thereafter, all low-frequency research performed in the United States and elsewhere was tainted because of the entry into and domination of the field by the Electric Power Research Institute. No subsequent scientific study can be presumed to have been performed by honest scientists for honest purposes. Giarola’s work, therefore, which Repacholi dismisses in such a cavalier fashion was, despite its technical shortcomings, a significant scientific study.
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COMMENT 73: Repacholi’s claim that I am “an advocate of using electromagnetic fields for bone repair” is false—I have never so advocated. Even if I had, what would be “interesting” about reporting that exposure to 5 kV/m fields caused a significant retardation in bone healing? Repacholi seems to assume that EMFs must be either good or bad, but that they can’t be both. This is the kind of neanderthal mentality that sits on the throne at WHO and purports to tell the world what the truth is. Repacholi might as well be reading goat entrails; he would probably get things right as often as he does trying to read the literature.

I did indeed report a threshold between 1 and 5 kV/m for the effects of low-frequency EMFs on bone healing in rats. I delivered the paper at Battelle Pacific Northwest Laboratories in 1978, at a symposium organized by Richard Phillips. I went into his lair with the intention of bearding the lion and did so by giving the work the strongest possible title it could sustain (“Power-Frequency Electric Fields and Biological Stress: A Cause-and-Effect Relationship”).

Following my presentation and its publication, Phillips received a contract from the Department of Energy to replicate my work. His initial studies were done at 100 kV/m, and the results he obtained were essentially identical to mine. Following a meeting between Phillips and Robert Flugum, Phillips’ friend at the Department of Energy and the contracting officer for the Department in the EMF area, it was agreed that the fracture-healing studies would be discontinued because their continuation could only emphasize the existence of the phenomenon of EMF-induced reduction of the rate of bone healing, something that was not in their interests.

Repacholi’s discussion of my work and its relation to that of Phillips is recklessly incorrect. Repacholi discusses scientific literature like a squid uses ink.
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COMMENT 74: Duh...What about the possibility that the rabbits weighed less than the controls because chronic exposure to the field partially destroyed their brains? It’s hard to imagine a more rabidly partisanist argument than the one given by Repacholi in this paragraph.

Portet and Cabanes worked for the French national power industry. Anyone who believes that they would be likely to perform honest EMF research simply does not understand how the power industry games the biology of EMFs.
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COMMENT 75: The pattern is utterly monotonous. Dr. X, who didn’t work for the power company finds biological effects due to EMFs. Dr. Y, who worked for the power company tries his damnedest to replicate the result, but fails to do so. Then Repacholi, operating under the assumption that Y >> X, concludes that there were no EMF-induced effects, and therefore that powerlines are safe.

Repacholi frequently succeeds with this argument because he is never called upon to defend it.
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The mechanism of absorption and interaction at low frequency and at high frequency are completely unknown. Repacholi therefore has no way of knowing that they are “completely different.” He simply asserts that is the case, as instructed by his lawyers.
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COMMENT 77: Hauf worked for the power companies. See Comment 50.

Repacholi’s argument contains the same monotonous error. See Comment 75.

There is no Kuhne. Perhaps Repacholi meant Kaune, who was the right-hand man for Richard Phillips during the 1970s and 1980s, which was the group that produced a huge number of worthless EMF studies on behalf of the power industry.

Hauf found nothing, so it is not possible to “confirm” his results; the best that one can do (from the industry perspective) is to find nothing. Nothing, however, confirms nothing.
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COMMENT 78: This is another example of argument described in Comment 75. In essentially every case Y and X did different experiments, often widely different. Such was the case for the binary opposition set up by Repacholi in this paragraph. Persinger applied a weak magnetic field; Hauf, in contrast, applied a strong electric field. In addition, the conditions of exposure were not at all comparable. Even if one took Hauf’s work at face value, it would simply be unreasonable to argue that it somehow overcame the implication of Persinger’s work.
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COMMENT 79: Repacholi argues that Gibson and Moroney found no EMF-induced effects in some of their measurements. It is a signature power-company strategy for its expert to begin a description of a study by pointing out the particular tests that failed to show any results—it’s what the industry lawyers call “putting the study in perspective.” Scientists typically accentuate positive results because, with two extremely limited exceptions, negative results have no probative value anybody can fail to find something. This is not the case for industry-controlled scientists. Their lawyers know that jurors expect experts to begin by talking about a study’s most important results. Putting the negative results first therefore tends to create the impressions that (1) negative results have meaning, and (2) the pertinent research is essentially negative.

Repacholi concedes that some tests showed an effect due to the EMF, but he argues that they were “good” effects because they showed “significant improvement” in performance. By means of this argument, the basic message of the study (that the EMF altered the activity of the human brain) is more or less suppressed, and attention is focused on the nature of that change (that it was “good”). The notion that “good” effects in EMF laboratory studies should not be a basis for health concern is an old industry shibboleth. I first saw it in a proceedings in New York where an industry expert was testifying about the effects of fields on cells in vitro. The results suggested that the fields caused cells to survive longer than the controls. “If powerline fields can do that, then let’s string them up all over the God-damned place,” is what the expert said. Here, Repacholi makes essentially the same argument. The problem, of course, is that the argument begs the question, which is not whether an EMF effect is “good” or “bad,” but whether it exists. Repacholi is like a barker at a carnival operating a shell game in which he puts the pea under one of the shells and begins moving them around to confuse his customer.

Another common industry argument aimed at misleading the layman is one that seeks to limit damage resulting from any degree of acceptance of the results on the part of the juror. The argument amounts to “Okay, maybe there were effects, but these results did not indicate a general effect on...” In other words, the effect was only on one measured parameter, which doesn’t mean that there will be effects on any other parameter. The fact is, however, that it is never possible to perform an experiment which reveals a “general” effect. All laboratory effects are specific; they consist of changes in the dependent variable chosen for study. As a dutiful automaton, Repacholi also makes this argument.

Still another deceptive strategy of industry experts in dealing with studies whose results are adverse to their client is to sandwich a reference to the offending study between a description of two studies performed by industry contractors or industry spokesmen that are, naturally, strongly pro-industry. Repacholi describes the work of Hamer (an independent scientist, not controlled by any EMF industry) between the work of Hauf and Sienkiewicz, whose views are controlled by the industry. The overall impression, Repacholi hopes, will be favorable to his client.

I had testified that animals exposed to fields exhibited classic signs of stress. It is no evidence against that hypothesis that “no obvious or simple mental deficits” were observed by Stollery.

You should note how effectively Repacholi packaged five grossly misleading arguments in only two paragraphs.

There was a famous judge in New York in the 1920s who gave the best explanation of the responsibility of an expert that I have ever read. He said that it was the expert’s responsibility “to tell the truth, in all its stark significance.” Repacholi is a perfect example of the negation of that prototype.
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COMMENT 80: Like a vampire bat sucks blood out of its victims, Repacholi sucks meaning out of the studies that report positive effects due to EMFs. In this case, Dumanskiy studied human subjects exposed to 15 kV/m, 1.5 hours per day, for 6 days, and observed an increase in blood glucose. The other investigators cited in this paragraph worked for the industry. None of them performed the same experiment, studied the same independent or dependent variables, or exposed the study subjects for the same time as Dumanskiy. Even if one accepted their negative results as credibly negative, those studies would be incommensurate with that of Dumanskiy.

Industry investigators are incredibly efficient at failing to find evidence that would jeopardize the public position of their employers; the only rational explanation is fraud. It is also important, however, to recognize an equally serious defect in their work that the argument made by Repacholi and other industry spokesmen based on the industry’s negative research is illogical. When someone drills a hole in the ground and fails to find oil, the logically proper conclusion is that there is no oil at that location. The result might have been quite different had the well been drilled 10 feet away. In other words, negative results never generalize. Only positive results can generalize.
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COMMENT 81: Beischer worked for the U.S. Navy and did his research at a Navy facility. He found that low-strength, low-frequency magnetic fields altered serum triglyceride levels in human subjects, and the results of his experiment were published in a Navy report (NAMRL-1180, July 1973). He concluded: “Barring the oversight of a crucial factor, the results of the present study strongly indicate that certain mechanisms of lipid management in the human body are influenced by an external, comparatively weak alternating magnetic field of low frequency.”

The Navy had a poor record for scientific integrity in the EMF area in the 1970s and 1980s. It rigged National Academy of Sciences committees, buried reports from its own committees when the evaluations were adverse to Navy policy, and spent lavishly to test experimental designs that were doomed to failure (see the discussion of Mathewson’s work at Comment 69). However, the level of scientific disorder within the Navy EMF program never sank to the level of depravity exhibited by the program run by the Electric Power Research Institute. So far as I know, for example, the Navy never fabricated data or buried adverse results in those instances they percolated to the surface of the Navy studies. Thus, it was possible for Beischer to publish an official Navy report that actually described effects due to EMFs in human subjects. Had the experiment been performed under the aegis of the Electric Power Research Institute, this result would have never seen the light of day. It should be no surprise that the Electric Power Research Institute, whose sense of morality is below that of a slug, would concoct a wild story to deprecate Beischer’s work, or that Repacholi, whose morality is as low as that of the Electric Power Research Institute, would refer to its myth as support for his testimony.

It is interesting to reflect upon Beischer’s fate. Like Schwan, Beischer worked in Nazi Germany during World War II and came to the United States in the late 1940s as part of Operation Paperclip, which was a U.S. program designed to enlist the services of German scientists on behalf of the United States Defense Department and its contractors. Unlike Schwan, who went off in the direction of rationalizing the rejection of any form of hazard associated with environmental EMFs, Beischer’s work tended to support that possibility. Because of his past, however, and his total dependence on the Defense Department for research support, he was totally under the control of the Defense Department. Soon after he published the triglyceride report he was forced into retirement. I was present during a conversation he had with Dr. Becker at about that time. Dr. Becker asked Dr. Beischer for more information regarding the triglyceride studies and Dr. Beischer replied, “I cannot say anything about it; they will not let me.”

After Beischer retired I located him and wrote to him (1917 Front Street, Durham, North Carolina), thinking that as a civilian, he might be willing to speak, but all my letters went unanswered.

Sander, Rupilius, and Eisemann worked for the power industry. Their work has no scientific value. In this regard it is no different than any other power-industry-controlled work that I have come across during the past 30 years.
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COMMENT 82: Just as a monkey who punches away on a keyboard will eventually write a line from Shakespeare, so Repacholi who continually searches for verbal formulas to express his distorted interpretations of the EMF studies will, by chance, say something truthful. Persinger’s work is “in contrast with” the reports of the industry hacks that he cites in this paragraph. Persinger found an EMF-induced effect, the hacks didn’t. Persinger’s work was honest, the work of the hacks wasn’t. Persinger studied the effects of a 10-gauss field, none of the hacks did such an experiment. In every salient way, Persinger’s work was indeed “in contrast” to the industry hacks cited by Repacholi.
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COMMENT 83: Repacholi concedes that weak electric fields (roughly corresponding to 500–1000 feet from the centerline of a typical high-voltage powerline) can affect human circadian rhythms. “Not to worry,” he says, because “everything goes away after about a week.” The logic reminds me of that of the president of the Lead Manufacturers Association who said that high levels of lead in the blood of women wasn’t a problem because lead passed the placental barrier, so a woman could get rid of the lead any time she wanted to by having a baby.

Repacholi is particularly fond of the circumlocution, “It is difficult to interpret these results...” He knows that the layman tends to mistakenly interpret that phrase to mean, “The evidence is ambiguous, and not worth bothering about.” He was skilled in psychological manipulation even in 1990, when he drafted the testimony. By the time he retired from the WHO in June, 2006 he was one of the world’s great masters of the technique of using language to mislead the public. As I listened to his speech at the BEMS meeting in Cancun, in June, 2006 I could only marvel at his ability to make it seem that environmental EMFs were as safe as mother’s milk.
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COMMENT 84:Again we see that a rational discussion of the health risks of environmental EMFs cannot take place until the ground rules have first been agreed upon. In this paragraph Repacholi makes a bogus distinction regarding EMF frequencies without first justifying the distinction.

In resolving the question regarding health risks of powerlines, to what extent and in what way should the results of human and animal studies at frequencies other than 60 Hz be considered? The question is partly scientific, but also incorporates subjective ideas concerning justice, fairness, and values. I believe that Repacholi’s dismissal of high-frequency studies is baseless, but the point is that the issue must be resolved prior to a discussion concerning the health effects of EMFs. It makes no sense to hold such a discussion without determining what exactly counts as evidence, and why.

Repacholi’s analysis was designed to reach a desired conclusion, rather than to engage in an honest and sincere effort to find the best truth possible. All manner of logical, rhetorical, and evidentiary errors are bound to occur when someone acts in that manner. For example, Repacholi dismisses Ericson’s work because the strength of the low-frequency fields was “extremely low.” The subjects had been exposed to high- and low-frequency fields, and adverse effects were reported. In the preceding sentences Repacholi took the position that high-frequency EMFs “bear no relationship” to the problem of evaluating the effects of low-frequency fields. What then is he supposed to do with a study that involved both frequency bands? Even if the game were played under his rules (high-frequency doesn’t count), it would still be reasonable to consider Ericson’s study because the effects observed could have been due to the low-frequency fields. This possibility is abhorrent to Repacholi, so he asserts that the study can be ignored because the strength of the low-frequency fields were “extremely low.” The argument is illogical because if effects were caused by low-frequency fields, then the results of the study would be highly damning to his clients (because they would suggest that fields weaker than those from powerlines but having the same frequency could produce adverse effects). There is simply No Exit for Repacholi.

The balance of the paragraph is the finest example of double-talk provided by Repacholi in this testimony. The language is aporetic, and I think intentionally so, because it is designed to dispute the evidence that I cited, but not to provide any particular reason for opposing that evidence (because there was none). When Repacholi finds himself in this situation, he typically uses equivocal terms or circumlocutions such as, “not conclusive,” “inconclusive,” or claims that the author did not “seriously address” some industry criticism.

In considering Repacholi’s sweeping criticisms of the work of so many investigators, it is well to bear in mind his background and experience, and the basis of his knowledge claims. He was trained only as a physicist, has no experience in performing laboratory studies, and by his own admission is not a researcher.

Repacholi’s testimony is simply an appeal to authority. In effect, he says, “I am correct, I know that EMFs do not cause health problems because that is the conclusion of WHO committees, the IRPA, the IARC, and so forth.”
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COMMENT 85: I believed that my conclusions were “completely founded” and “backed up by laboratory and epidemiological studies,” and that whether or not they were “completely out of line with WHO” was irrelevant. The point is that these are assertions or conclusions held by Repacholi, not scientific analysis, which was the duty he owed the court.
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COMMENT 86: Of course Anderson and Phillips “had major questions.” That’s exactly what they were paid by the Electric Power Research Institute to do. That was their job. Repacholi was fully aware for whom Anderson and Phillips worked, but he never disclosed that fact to the court.
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COMMENT 87: Stollery’s work, which was controlled by the British power industry, is a good example of how a well-conducted study can be rigged at the design level to almost guarantee that results adverse to the industry won’t happen. First, the studies did not involve EMFs, but rather electric currents applied to the subjects. Second, the parameters measured bore no validated link to physiological stress (which was the hypothesis that the British power industry was trying to undercut). Third, the studies had almost no statistical power to detect any effect due to the electric current, if it occurred. Fourth, a conclusion that there were “no obvious effects” is an argument appropriate only for children to make. Nevertheless, the work was published in the British Journal of Industrial Medicine. In my experience, when something like this happens, it”s usually the result of political pressure brought by the industry on the journal, and it is a particularly serious problem among the elite British medical journals.

Essentially all of the industry-supported studies involving the effects of EMFs on EEGs described here by Repacholi were negative. We now know that this was because of the incompetence of the investigators, and was not a result of the inability of the EMFs to affect brain electrical activity. Within the context of this testimony, however, the point is that even when Repacholi gave this testimony there were reports that reached the opposite conclusion, that is, reports that described effects of EMFs on brain electrical activity. Repacholi simply neglected these reports when he drafted this testimony.

Hauf, as I discussed previously, was a hack scientist working for the German power industry. Dino, on the other hand, was a competent engineer. The deception practiced by Repacholi in this paragraph is his citing of Dino’s work for a proposition that even Dino would agree he was not competent to evaluate. I knew Dino well. When he used the term “stress” he meant something akin to “pain” or “electrical shock.” He did not mean physiological stress such as I described in my testimony and Repacholi is attempting to denigrate in this paragraph.
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COMMENT 88: Corticosterone is increased after acute stress, but can be decreased in the face of chronic stress. Repacholi simply doesn’t know the territory.

The work of Free looks good because he published only the results of experiments that came out the right way as far as the power industry was concerned. When the experiments didn’t work, Free simply buried the data. When I obtained reports of his studies through the Freedom-of-Information Act, I could see that Free maintained two sets of books, and the public saw the results of only one set.

Graves was a pleasant man, but extremely pliant. Whatever the power industry needed saying, Graves was up to the task. At around the time that Repacholi gave this testimony Graves had quit his job as a professor at Penn State and took a position as “Chief of Staff” for Tom Watson, the Darth Vader of EMF litigation in the 1980s and 1990s. If you wanted to defend against a charge that your high-voltage powerline or your cell telephone caused cancer, Tom Watson was your man. It hardly makes sense to quote the work of Tom Watson’s chief of staff as support for the proposition that powerline EMFs are safe. This is particularly true considering that Tom Watson’s lawyer colleagues were involved in this case.

Quinlan and Portet worked for the power industry in their respective countries. The results of their research was therefore foreordained.
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COMMENT 89: The testimony is misleading because the human studies mentioned by Repacholi were not designed to test the stress hypothesis.

The operative metaphor in this paragraph is “bulk.” Repacholi conceives of laboratory experiments as grains of sand. Red grains represent positive results in EMF studies and green grains represent no effects. Red is bad. Green is good. The red grains are placed on one side of a scale and the green grains are on the other. Truth is indicated by which side is heavier. Certainty is indicated by how quickly the scale reaches its final state. It’s easy to see that someone who looks at the world this way can establish his version of the truth by simply painting enough grains of sand with the right color. The power industry painted many grains green. Thus, within Repacholi’s framework, his conclusion is true. The point is, however, that his framework is an aberration.
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COMMENT 90: The phrase “adverse health effect” encapsulates the hurdles that the power-industry mindset envisions must be overcome before they will bury powerlines or take other remedial steps to eliminate EMF exposures. First they argue that a study must show an “effect.” But every biological study that does so invariably triggers a set of roughly similar studies designed by the industry to convey the notion that, in the original study, there was no “effect.” So, in the industry perspective, there are no “effects.”

Second, even if there was an effect, according to the power-industry mindset it must involve “health.” But there is no parameter that can be measured in a laboratory investigation that equals “health” because it is a normative state not a particular measurement. Thus, every physiological, behavioral, biochemical, electrophysiological, or biological endpoint that can be measured by an investigator can and routinely is attacked by industry experts as being arguably unrelated to “health.”

Third, assuming that a health effect was demonstrated, the power industry attitude is that the effect must be proved to be “adverse.” No industry spokesman, expert, investigator, or consultant has ever defined what an “adverse” health effect is. Some courts have held that every biological effect observed in an animal system must be presumed to be “adverse,” but the industry position historically has been exactly the opposite. Whatever effect is reported is mechanically opposed by an industry argument to the effect that there was no evidence to indicate that the effect was “adverse.”
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COMMENT 91: The argument here is particularly aggravating because it is so highly misleading.

In his testimony Repacholi points to values of electric and magnetic fields measured up against household electrical appliances that might be used for only a few minutes a day, and compares the exposure to these fields with that produced by the fields from a high-voltage powerline. The facts are: (1) almost all published measurements are made unrealistically close to the product that is the source of the fields. Consequently, the average exposure experienced by the user is invariably far less than the maximum field measured in the spot measurement. Fields from powerlines, in contrast, expose the entire subject. (2) Fields from typical household appliances are experienced for relatively brief periods, whereas exposure to fields from high-voltage powerlines are vastly more chronic.
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COMMENT 92: Repacholi’s argument is again grossly misleading.

I pointed to the clinical use of EMFs to make the point that it’s simply absurd to regard EMFs as clinically useful tools when they are administered to a patient under controlled conditions, but that EMFs of comparable strength, when administered to people by power companies under uncontrolled conditions are completely without potential health effects. Even an idiot can follow this argument, which leads to the conclusion that powerline fields are potential health risks, not to the conclusion that powerline EMFs need not be considered because the power company is not trying to produce beneficial effects. This, I think, is Repacholi’'s slimiest argument in this entire testimony.

Whether the biological effects and health hazards associated with EMFs are due to the electric field, the magnetic field, induced currents, or any of a myriad other aspects of the electromagnetic energy remain unresolved issues. It is simply not true that the clinical effects “almost certainly (are) a result of induced currents.”
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COMMENT 93: In my view, nothing Repacholi or the WHO committees have done is “perfectly valid.” Indeed, it is far closer to the truth to say that their work is “perfectly invalid,” because in the WHO documents and in this testimony one can find every species of misleading, dishonest, and false argument that has ever been advanced by the power industry during the 30 years that the dispute has been ongoing.
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COMMENT 94: The WHO reports actually resulted from a superficial analysis of the literature by scientists working for the power industry, with the basic wordsmithing being done by Repacholi himself. It is not difficult to accept them as consensus agreements, but it is not difficult to establish a consensus among like-minded people. A committee of phrenologists would likely agree that an analysis of the bumps on somebody’s head could reveal his character.
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COMMENT 95: The EIS in this case was a ponderous tome that went into excruciating detail regarding numerous trivial matters, while completely skirting everything of potential significance regarding impacts on human health due to the EMFs. In this regard, the EIS was like essentially every other EIS I have encountered. One expects that an EIS will be drafted in this way because it is a report written by the power industry that, on its face, is designed to support decisions made by the industry in particular cases. Just like the company’s testimony in chief in this case, its EIS was replete with lies and distortions.
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COMMENT 96: The WHO reports contain numerous assertions of safe levels regarding EMFs. Because I know many of the details of the process I could see that it was corrupt. As I thought about the process I came to understand that the disorder was deeper than simply a collection of national power industries attempting to preserve and protect their autonomy and their right to do as they please. The committee promulgated safe levels, and I came to see that’s exactly what they were, namely EMF levels that were “safe.” Only when one asks, “For whom are they safe?” can the true nature of the process be appreciated. The levels are actually “safe” for the power industry because they allow it to continue business as usual. There was never any significant intention that the levels should be “safe” with regard to the people who would be exposed to the fields.

I think essentially the same thing can be said with regard to any kind of a “safe” level. Every such level that I know about has been set to protect the interests of the authority that created the group which chose the levels, not the safety of the people who will be exposed to the agent.
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COMMENT 97: The fact that some papers are reviewed by the industry representatives on the WHO panels, or by Dr. Graves who was the chief of staff for one of the lawyers involved in the preparation of the power company’s case, does not entail the idea that the work was given appropriate weight. The work was butchered by the WHO panels and by Graves in the interests of the industry.

The reason the 25 low-frequency papers were not reviewed by someone else (which is the gist of the point Repacholi makes) is irrelevant. The reports involving microwaves, radiofrequency effects, and bone-healing were highly probative regarding the question whether the powerlines would be safe because these reports showed that EMFs too weak to cause cooking of tissue could produce biological effects. This is the salient issue in all EMF litigation from this issue arises the liability of the defendants.

The WHO and Graves’ reports were adequate only in that they showed the depth of the disorder in modern science, which was too easily manipulated by the power industry.

Repacholi’s testimony highlights the disorder in law because the rules of evidence (at the time this evidence was adduced) not only tolerated but actually encouraged abusive use of scientific narratives, at task at which he excelled. Several years after this testimony the law of evidence in the United States regarding expert scientific opinion changed dramatically with the Supreme Court’s unanimous decision in the Daubert case, which removed a fundamental impediment in the law of evidence known as the Frye rule. Unfortunately, the fundamental disorder in modern science remains.
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COMMENT 98: The EIS was a fraud, but a useful fraud for Repacholi’s purposes.

The EIS essentially said that powerline EMFs were safe because WHO and Graves said so. One need not be familiar with details of the corrupt nature of those reports to understand that the EIS process (and hence Repacholi’s reasoning) is defective. The original idea behind the EIS process was to foster the notion that it was a good thing to think about what would happen to the environment before undertaking a large-scale project. However, the EIS process was a restriction on the power companies which really wanted to be free to do anything they pleased. They accepted the use of EIS’s because it was legally required and politically expedient to do so, but they subverted the original intent by creating organizations that would contract with the companies to provide reports that reached whatever conclusions they desired. This strategy began with Chauncey Starr at the Electric Power Research Institute in the late 1970s, and has continued unabated since then. In the present case, the Australian power company hired a friendly firm who agreed to look only at reports and analyses that supported the company’s position.
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COMMENT 99: This is vintage trickyTom Watson. Any lawyer preparing to go up against him ought to prepare for this strategy.

Plaintiffs’ lawyers almost universally fail to properly vet the experts they present, incorrectly figuring that the expert knows best. Experts typically approach legal case, and are undefined, like obscenity. As Richard Feynman was fond of pointing out, nobody knows the “mechanism” of anything, even gravity. Even so, only a fool denies its existence.

Liboff cast his testimony in terms of his ideas concerning the mechanism by which powerline EMFs produce biological effects. That was a mistake. The issue in the case was whether EMFs caused biological effects. The question of how such effects occurred was legally irrelevant as well as being scientifically unanswerable. An expert witness who propounds a theory regarding “how” EMF-induced disease is mediated is essentially trying to do the impossible, and is open to effective attack by a clever tactician such as Watson. That’s what occurred in this case.

I never testified that any field was the “source” of any interaction. I testified only that electric fields produce biological effects, suggesting that powerline electric fields were health hazards. In addition, I testified that magnetic fields produce biological effects, suggesting that powerline magnetic fields were health hazards. I never said anything about mechanisms, and I steered clear of irrelevant considerations such as those introduced by Liboff and capitalized on by Watson and Repacholi.

Tom Watson has spent more than 20 years trying to elicit testimony from me regarding assertions of “mechanisms” by which fields interact with biological tissue. It hasn’t happened yet, and it’s not likely to happen in the future. The reason is that such testimony would be irrelevant to the health-risks issue, and would only create collateral and confusing cross-examination, making it especially incomprehensible by the judge and a jury. This is almost always the condition Tom Watson seeks, and the condition I always try to avoid.
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COMMENT 100: He claims that in vitro results have “only limited applicability to health-risk assessment,” and that “once an effect is found in vitro, it must also be found in vivo...” However, both these propositions are debatable, and their applicability must be settled prior to, not during or after scientific testimony formally designed to evaluate the health significance of research.

I think the propositions are foolish and unwise, but they are not illogical or impermissible. The question is, therefore, should they be accepted as part of the ground rules of the debate. It is simply a measure of Repacholi’s chutzpah that he assumes his personal view on these matters is correct, and governing.

Repacholi routinely sets himself up as an all-knowing font of knowledge and Decider of Values. His record in this regard during his tenure at WHO set a new standard for the extreme level of dogmatism that he injected into EMF health debates.

“Very preliminary” is another frequent compound Repacholi circumlocution.
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COMMENT 101: This is the same story that we have seen many times in this testimony, and throughout Repacholi’s career as the major domo at WHO. On the one hand there are reports in the literature by independent scientists that suggest the existence of biological effects due to exposure to low-frequency EMFs, and on the other hand we have the ipse dixit of industry panels. Repacholi “evaluates” the two sources and concludes that the truth must be what the rigged panels say it is.
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COMMENT 102: Ah! The first paragraph is completely correct, but not surprisingly, completely misleading. The available literature was incomplete, is incomplete, and shall always be incomplete. It’s simply a stupid thing to say about scientific data because it’s so obviously true all the time.

It is worth reflecting on how the OTA report came about. The OTA was under the direction of John Gibbons, and he was conducting a broad study of the future of the electric power industry. Gibbons was personally offended by the testimony that I had given to the effect that high-voltage powerlines were a health risk. He contacted the Department of Energy, which was the chief federal agency then serving as a proponent of high-voltage powerlines, and he was encouraged to undertake a study of the issue as a sub-task to the broad study in which he had been engaged. The Department of Energy recommended Granger Morgan to undertake this sub-task. At the time, Granger Morgan was funded by the Department of Energy and the Electric Power Research Institute. Morgan’s stated opinion regarding high-voltage powerlines was that there was no real biological problem, only a misperception of the risks by the public which was ignorant regarding scientific matters and therefore prone to be misled by mischievous scientists such as me. Not surprisingly, Morgan’s report buttressed Gibbons’ personal position.
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COMMENT 103: Wertheimer published a paper linking childhood cancer and exposure to powerlines, and the power industry has attacked the study continuously for 27 years, like a swarm of African bees attacking a good-natured botanist walking through the woods looking for daffodils. As vicious and concerted as the attacks on her work have been (the comments by IRPA and Cole are among the most vicious), it’s clear that her work will survive long after her attackers are forgotten.

I knew Cole. He had a morose, sullen disposition and never smiled, and was an ideal power-company witness because he was nasty, negative, and against everything. He almost made a living out of testifying that nothing made by man could be judged a health risk on the basis of epidemiological methodology, which was the subject that he taught. In other words, he was a professor in a subject that he claimed was essentially incapable of accomplishing anything. It’s only natural that Repacholi should cite Cole as an authority.
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COMMENT 104: The argument is no more than an infinite regress, because every epidemiological study is problematical, and no epidemiological study is sufficient to determine if anything is “real.” The kind of reality involved with EMF-induced health risks is in the mind, not only in the world. Consequently, the issue is never strictly the reliability of what is found, but rather what the agreed meaning of evidence will be, if found.
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COMMENT 105: The results of this study eventually were published in a peer-reviewed publication. That, however, did not satisfy Repacholi. He invented new bases upon which to attack her work. The point is that nothing ever satisfies him because he lacks the integrity and competence necessary to honestly evaluate scientific research.
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COMMENT 106: The unclarity is in Repacholi’s mind, not Liboff’s testimony. The “it” in the last sentence is an expletive that doesn’t refer to anything (like the “it” in the sentence, “It is raining.”).

A witness who testifies that something is true because WHO or IRPA, or any other purported authority says it’s true ought to be shot. Such a testimony is the rankest form of hearsay, and it presumes that words rather than reasoning can be authoritative. The founding principle of the world’s first scientific society, the Royal Society in England was “nullius in verba” (“take no man’s word”). Repacholi would reverse this principle and take us back to the times when truth was simply a dogmatic assertion.
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COMMENT 107: The WHO committees were always reactionary, and hence always behind the curve regarding the nature of the evidence that supported assertions that EMFs were health risks. That’s the way the power industry functioned, historically. It denied the existence of risks on the basis of what was good for its business, not because that view was justified by the scientific evidence. Given the perspective of the industry, it’s clear that no evidence would ever be sufficient for the industry to agree that EMFs were health risks.
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COMMENT 108: Sometimes Repacholi’s tongue gets wrapped around his nose, and we are treated to paragraphs such as this. The public, generally, has the idea that scientific testimony must be precise or exact, and carefully checked out because, after all, the witness is testifying under oath. Actually, the reverse is true. Scientific experts often produce testimony that is nonsensical, misleading, incorrect, ambiguous, biased, or just plain wrong. They usually don’t have to worry about being tripped up because most lawyers and judges can’t talk the scientific lingo, and few attorneys bother to present scientific testimony in a way that can be understood by the layman. It’s almost always in the interest of the power industry not to do so (because confusion and ambiguity always works to the benefit of the power industry which, after all, is simply seeking to maintain the status quo). The worst experts are always those like Repacholi who testify for the power industry. This is because they are well schooled by people like Tom Watson regarding what to say and how to say it to create maximum confusion and ambiguity. So far as I can tell, there has never been an effective cross-examination of one of Watson’s experts which is a monument to his skill, and the general lack of technical competence on the part of plaintiffs’ attorneys.
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COMMENT 109: For essentially his entire career, H.B. Graves worked for the Electric Power Research Institute or for Tom Watson or other power industry lawyers. It’s foolish for Repacholi to imply that Graves was unbiased.
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COMMENT 110: It was Repacholi himself who wrote the WHO reports. This testimony is therefore entirely circular: he says that his opinion is that his opinion is correct.
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COMMENT 111: The reports by Rodan and Bassett involved the effects of EMFs on bone. Repacholi previously denied that bone studies were relevant to the issue of health risks of powerlines (Comment 97). Thus, Repacholi talks out of both sides of his mouth: he said earlier that the studies don’t count, but he says here that his WHO reports took them into consideration “to form the overall picture...”
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COMMENT 112: Repacholi can’t testify about the reason studies such as Marron’s “are normally conducted.” How would he know that? Further, if he actually read Marron’s work he would see why Marron says the studies were conducted, namely to evaluate the health risks due to low-frequency EMFs produced by a huge antenna that the Navy planned to build in Michigan.

The industry mantra, espoused here by Repacholi, is “understand mechanisms first, then decide what’s safe or unsafe.” The attractiveness of this scheme for the industry stems from the impossibility of every inferring mechanisms in any reliable or certain way. The industry is saying, in effect, “First show me that you can lift yourself off the ground by your bootstraps, then we will consider changing our present corporate policies.”
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COMMENT 113: A core problem here, throughout Repacholi’s testimony, and throughout the testimony of power company witnesses generally is that they have never really been required to explain their reasoning or describe the methods by which they reached their conclusions.

Liboff pointed to Adey’s work and explained why it was supportive of the idea that powerlines are health hazards. Repacholi’s response is simply to say that he has considered this previously and that it is not so. He never explains why it is not so.
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COMMENT 114: Repacholi says that Sulzman found effects, but that the threshold for effects in the study was above that produced by the powerline. Repacholi makes the assumption that experiments relevant to the powerline must show effects at the field strengths of powerlines (not higher) to be considered relevant. That position is unjustified and has not been advocated in any formal proceedings by even the most rabid industry spokesman. Further, even if one granted Repacholi’s assumption, there was no nexus between the Wilson study (which was done at a field strength comparable to that of powerlines), and the Sulzman study.
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COMMENT 115: Repacholi labors to undercut the project Henhouse studies, which are, in my judgment, the second clearest line of experimental evidence indicating the nature of the biological changes produced by EMFs. He commits the same historical error that all power industry spokesmen have made since the inception of the health-risk problem in the 1970s, that of assuming nature to be a machine that always functions in the same manner under what appear to be the same circumstances. Thus, when the “same” experiment is performed in two different laboratories and the “same” results are not obtained, the results are regarded as “conflicting” and somehow contaminated by experimental error. The truth, however, is that the results are not conflicting because the assumption that nature was a machine (that is, obeyed linear physical laws) is simply incorrect.

One can see how this came about by considering the results from the Project Henhouse studies.

TABLE 1. Proportions of normal living embryos (means ± SE). Approximately 100 embryos in the MEF and in the control group were studied at each laboratory. On the basis of ANOVA, there was a significant difference between the EMF and control groups, F91,54)=12.09, P=0.001. See Berman, E., Chacon, L., House, D., Koch, B.A., Koch, W.E., Leal, J., Løvtrup, S., Mantiply, E., Martin, A.H., Martucci, G.I., Mild, K.H., Monahan, J.C., Sandström, M., Shamsaifar, K., Tell, R., Trillo, M.A., Ubeda, A., and Wagner, P.: Development of chicken embryos in a pulsed magnetic field, Bioelectromagnetics 121:169-187, 1990.

Principal Investigator Location Sham-Exposed Exposed
A.C. Martin London, Ontario, Canada 0.936±0.024 0.794±0.024
K.H. Mild Umeå, Switzerland 0.916±0.026 0.874±0.026
J.C. Monahan Rockville, MD, USA 0.903±0.030 0.778±0.030
J. Leal Madrid, Spain 0.829±0.041 0.796±0.057
W.E. Koch Chapel HIll, NC, USA 0.784±0.027 0.785±0.035
G.I. Martucci Las Vegas, NV, USA 0.730±0.050 0.699±0.044

There was an effect due to the EMF when the studies were evaluated as a group, using an ANOVA. In addition, some individual studies showed a statistically significant difference between the exposed and sham-exposed eggs. Repacholi wants to argue that since a statistically significant difference wasn’t seen in all of the studies, that therefore the evidence that powerline EMFs can affect skeletal development is inconsistent and unreliable. That, however, is simply the industry’s self-serving interpretation of the results, which is accomplished by employing the assumption that real effects must be linear.

An even clearer example of the absurdity to which the assumption of a linear model leads is provided by consideration of the mouse multi-generation studies performed by Richard Phillips.
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COMMENT 116: Actually, what Liboff did is the only procedure that makes sense. Attempting to consider the negative studies referred to by Repacholi only creates confusion because those studies were simply rigged industry research. If one is going to make a decision regarding health risks by employing experimental data, banal as it may sound, the data relied upon must be produced by honest scientists, honestly trying to uncover truths about nature. That is almost never true of industry-supported research.
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COMMENT 117: All epidemiological studies are inconclusive in the sense that doubts also remain. Repacholi simply berates the obvious.

It is not enough to say that a blue-ribbon committee supported a position without inquiring into who appointed the blue-ribbon committee, and what the allegiances of the experts on the committees were. In the cases cited by Repacholi, those allegiances clearly belonged to the power industry.
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COMMENT 118: Even if one accepted the assumption that Trent’s work had some probative value and was honestly done and therefore reliable, the structure of this argument would still make no sense. One can support a proposition that EMFs affected DNA without showing that EMFs affected DNA in every experiment. To insist on such a criterion, which in effect is what Repacholi does, is crazy because it’s always possible for somebody to not find something, and there is absolutely no shortage of experts willing to do it. If that’s all it took to undercut a positive finding, then there would be no possible means by which one could ever infer that anything was a health risk.
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COMMENT 119: I know Carl Blackman. Michael Repacholi is no Carl Blackman. They live in different universes. Blackman is thoughtful, sincere, and honest. When he sees a weakness, or a possible weakness in a study, whether it is someone else’s or his own study, he raises the point in honest dialogue in an attempt to understand what the best truth is. Repacholi is the opposite. He denies all weaknesses in the position of his employer, and he viciously attacks anyone who concedes that some part of their work was not perfect, or absolutely clear.
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COMMENT 120: Repacholi does not analyze Dr. Liboff’s model, but rather an absurd parody that he himself has created. Dr. Liboff has spent a career honestly seeking the best truth possible regarding the biological effects of EMFs, and he has produced many fine and insightful publications. Repacholi, in contrast, has spent a career obfuscating the truth about EMFs and has never produced anything worthwhile. For Repacholi to criticize Liboff about the physics of EMFs is like Genghis Khan criticizing Emily Post about etiquette.
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COMMENT 121: I am familiar with the process by which the scientific advisory panel of the New York Powerlines Project was appointed. The panel were essentially controlled by the Power Authority of New York, which was the power company that put up the money for the project and had veto power over the appointment of every panel member. It is to be expected that the power company would attack results that were inimical to the power industry.

Cohen’s work was not a replicate of the work of Winters and Phillips; Repacholi’s testimony in this regard is untrue.

Finally, it is not true (as Repacholi implies) that the criticism of Winters was related to the work cited by Liboff.
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COMMENT 122: No agency of the federal government in the United States “sanctioned” any WHO report, or the Graves report. In fact, not even WHO sanctioned the WHO report (a disclaimer to this effect can be found in each such report).

It is not possible for any document to be authoritative. The best that one can say is that the evidence and reasoning described in the document indicate that the authors are authoritative, in the sense that their judgment can be relied upon. However, no blue-ribbon committee comprised solely of experts who represent the power industry can be properly considered to be authoritative because people who think the same way cannot debate one another.
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COMMENT 123: Undoubtedly they were meant to be relied on. The question, however, is whether they deserve to be relied on. Nothing that the power industry has done in the 30 years that I have followed its activities in the area of EMF-induced bioeffects indicates that any of the research that it funded or the panels that it crated deserve to be relied upon.
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COMMENT 124: The WHO and Graves reports are fine examples of the harm that results when one accepts the opinion of people with advanced degrees without inquiring into the bases and biases behind those opinions.
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COMMENT 125: Unfortunately, the Australian court accepted this conclusion from Repacholi.
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COMMENT 126: Repacholi doesn’t know what I believe. See Comment 99.
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COMMENT 127: Notice the heavy reliance on terms that seem black-and-white, but that are completely undefined by Repacholi: “established,” “confirmed,” “facts,” “known,” “authoritative.”

Repacholi has made no attempt whatsoever to tell the reader what he means by these terms. It’s not possible to give a Socratic-type definition, but it is possible, and necessary, to at least define them by listing examples. This is the only way to avoid a situation where witnesses talk past one another.

If Repacholi gave examples of where environmental factors have been “established” or “confirmed” as causing disease, then it would be possible to assess the criteria that he thinks appropriate for supporting such judgments. Then the appropriateness of his criteria could be debated. Repacholi, however, studiously avoids giving any indication of what he means by the pivotal and dispositive terms that he uses because he is interested only in winning for his client, not in finding the best truth.
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COMMENT 128: Beneath Repacholi’s double-talk is a serious issue, one that has never been addressed in any court. Delpizzo is an epidemiologist, an expert in analyzing the kind of non-experimental studies in which associations are sought between factors of interest. He analyzed the epidemiology involving powerlines and cancer, and concluded that there was an association. Given the way the studies were designed, the basis of the association is much more likely to have been the magnetic field rather than the electric field. Consequently, he hypothesized that the association he described was based on the magnetic field produced by the powerline.

Suppose, however, that there were no such studies reporting a positive association, or only a few such studies. What could an epidemiologist conclude? It could not be that the powerlines were safe because an important component of the evidence (in my view, the vastly more important component) consists of laboratory studies involving animals exposed to EMFs. Thus we see that an epidemiologist, even under the most favorable conditions for the power industry, cannot conclude that powerlines are safe, because no epidemiologist I know of is also an expert in laboratory studies.
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COMMENT 129: There’s no such thing as an “authoritative document” as Repacholi uses the term in this paragraph. Documents consist of words, and words do not have unique meanings. And if ever there were authoritative documents, they wouldn’t be authored by Repacholi, or Graves.
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COMMENT 130: A “letter to the editor” in the journals referred to by Repacholi is a formal scientific communication that is peer-reviewed. Repacholi is flat-out wrong.

Repacholi’s criticism of the epidemiological studies is silly because it is always true that “in no way was it possible to identify the carcinogenic agent.”t; For example, the carcinogenic agent in cigarette smoke has never been identified. No purpose whatever is served by making a criticism of the EMF epidemiological studies that also applies to every epidemiological study. To be valid, a criticism must be discriminatory in this sense.
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COMMENT 131: It’s clear that Repacholi is confused, but that’s an indictment of his lack of knowledge, not a shortcoming in the published research.

Again, all epidemiological studies suffer from lack of statistical power, and from inability to quantitate the exposure of people to the toxic agent. Repacholi isn’t commenting on the EMF epidemiological studies, but rather on the nature of epidemiological studies.
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COMMENT 132: All epidemiological studies are methodologically flawed in that they are unable to establish a causal relationship. Again, Repacholi’s comments are nondiscriminatory.
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COMMENT 133: In Paragraphs 269–284 Repacholi makes the same dreadfully weary arguments that he made elsewhere in his testimony, and to which I have previously responded.
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COMMENT 134: This testimony exhibits every species of disorder that occurs in modern-day science. The low moral and intellectual levels that Repacholi displayed here can be found in the testimony of most other industry experts. A great danger, in my view, is that the public will come to see all scientists as no more reliable than politicians or used-car salesmen, which is the standard of truth and accuracy that Repacholi meets. If the public adopts that perspective, there is no reason to expect that it will continue to allow use of its tax dollars to support science.
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