Wednesday, February 29, 2012

What are School Districts Waiting for if Safety of our Children is really their Priority?

Feb. 16, 2012

Dr. Terry Sullivan
Superintendent, Kamloops/Thompson School District No. 73
1383-9th Ave.
Kamloops, BC
V2C 3X7

Dear Dr. Sullivan:

I realize that WI-FI in the schools is an increasingly controversial and divisive topic, but I trust you will read the following with an open mind, as I write as a concerned parent that has spent many hundreds of hours in the last six months educating myself on the potential hazards of wireless radiation exposure. I don’t consider myself an expert by any means; however I do consider myself to be reasonably informed on this topic.

My concerns about the current situation, with WI-FI currently installed in most of the district’s schools, are many. First and foremost, is the potential health risks associated with prolonged, cumulative radio frequency radiation exposure. Many experts in the field have testified that the Safety Code 6 limits are far too high, do not address biological non-thermal effects, and do not sufficiently measure all potential effects of cumulative microwave radiation exposure. EMF and EMR exposures can cause a wide variety of health effects to the general public. Since Health Canada has approved some “Therapeutic Uses” for specific forms of EMF treatments proven to heal at energy levels far below current public exposure standards, the biological activity of electromagnetic fields cannot be denied.

Regarding current regulations, there are no SAR values for children, pulsed frequencies, or long-term exposure. This is because SAR values are based on a short-term (6-minute average) exposure to protect solely against heating a 6-foot, 200-pound adult male, not a child. Children’s bodies as you know, are much smaller, radiation is more readily absorbed through their thinner skulls, and their immune and nervous systems still developing. During the growth process as cells and DNA multiply, damaged cells and DNA will also multiply. Further, this guideline is based on occupational exposure, not continuous bombardment for 1,200 hours per year, and was never meant to address widespread chronic exposure, exposure in schools, or non-thermal effects.

On May 31, 2011, the World Health Organization’s (WHO) International Agency for Research on Cancer (IARC) classified radiofrequency electromagnetic fields as a Class 2B carcinogen (possibly carcinogenic or cancer causing to humans). They cited biological effects recognized in adult cellular telephone studies for their decision. This categorization by the WHO prompted Health Canada to issue an advisory calling for prudent avoidance of cellular phone use among children and youth, and contrary to what Health Canada has stated, this 2B classification was confirmed by WHO’s Dr. Jonathan Samet to include RF/EMF from ALL wireless devices. A school would never allow DDT or lead to be sprayed or painted on school walls, yet these things are in the same Class 2B category as emissions from WI-FI, which should be treated in the same manner.

There have been no long-term studies of the effect of chronic microwave radiation exposure on children, because, in the words of Health Canada's Beth Pieterson, "there are large ethical issues on conducting studies specifically on children", yet Health Canada condones exposing our children to this relatively new, and insufficiently studied technology. Top medical and radiation experts have repeatedly stated that there is NO safe level of exposure for children.

From the recent O.E.C.T.A. Health and Safety Committee’s report on WI-FI:
“When a WiFi network is turned on, any radiation exposure would be only due to the radiation emitted from the wireless transmitter’s beacon signal, with little or no use of clients on the wireless network. Each wireless device that connects to the network is a new non-ionizing radiation emitter that opens a new exposure stream over and above the beacon signal strength, which will add to the overall exposure of anyone in the nearby field.

Often, testing done to measure the impact of the radiation from the wireless network is done based on the transmitter’s beacon signal only, and does not take into consideration the impact of having multiple clients on the network at the same time. If the long-term goal is to encourage widespread use of the wireless network by personal electronic devices such as iPads, iPods, smart phones as well as notebooks or laptop computers, then exposure levels to this radiation will be unpredictable and higher than simple measurements would imply.

If ‘safe’ implementation is based on emissions being lower than Health Canada’s SC6 TLV of 1000 μW/cm2, then employers must ensure that this limit is not breached through a hazard control program that should include periodic field monitoring.”

Recently I asked SD73 Director of Information Technology, Mr. John Cuzzola “whether any RF radiation has been employed in the schools, and if so in which schools, by whom, by what method(s), and what the results were in regards to whether radiation levels are below Health Canada’s limits set out in Safety Code 6.“

Mr. Cuzzola stated, “We currently do not do any such testing on the equipment. All equipment used has passed CSA inspection and testing.” The CSA, which certifies electrical devices for electrical safety, has stated that it does not do any testing for the safety of microwave exposure from WI-FI. It says that it does not declare that WI-FI is safe. Surely, as persons charged with ensuring the safety of our children you must be aware of this fact and realize the responsibility to accurately test and report is yours?

My question to you Mr. Sullivan is: Why is this testing not being carried out to ensure compliance with Health Canada’s regulations? If each personal device accessing the network is emitting its own additional field of radiation, along with the radiation from the WI-FI routers, how can you possibly know, and prove, that radiation levels in the schools are in compliance and “safe”?

I have heard the school board repeatedly refer to Health Canada and local Health Units. I find this to be quite contradictory. If the District does in fact follow Health Canada’s safety guidelines regarding radiation exposure levels, as you have indicated previously in interviews with the local newspaper, it would seem that encouraging and enabling the use of personal wireless devices to be a stark contradiction in governing policy. How is it that when it comes to WI-FI safety you heed Health Canada’s guidelines, but yet don’t heed their advice on cellular phone use by children? I don’t believe that education health and safety policies are put in place only to be cherry-picked according to a school board’s whims and desires.

Health Canada's repeated reference to "the weight of evidence" offers me no comfort. Using a "weight of evidence" approach, 40% of the studies being done could demonstrate adverse health effects to WI-FI, yet "the weight of evidence" would still favour using the technology. Dr. Henry Lai, University of Washington did a study on industry funded science which showed that only 25% of industry funded science found biological effects, whereas 75% of independently funded science found biological effects.

Reputable and conscionable scientists that publish positive effect findings are being discredited by industry-funded scientists failing to “replicate the results” by using questionable methods and subtle differences in methodology that are indiscernible to anyone but their peers. Scientists who have formerly conducted industry funded studies have stepped forward with statements attesting to the fact that their (positive effect) findings have been suppressed. These same scientists soon found their research careers over; their funding cut off, and their reputations viciously attacked.

This is not the scientific community working together to establish factual data. This is industry manipulation to obtain results that it desires and the sabotage of legitimate scientific evidence; and these are not new tactics. As with asbestos, DDT and lead, related industries also attacked the researchers that published positive findings showing harm from these things; things that among others, Health Canada assured us were safe. Health Canada is not infallible, and has been wrong many, many times in the past, sometimes with disastrous results. We would be naïve to believe that there is not interference with science by an industry with so much at stake financially. Consequently, Health Canada's seal of approval is insufficient for me.

Allow me to use fetal alcohol exposure to illustrate a huge duality in Health Canada's risk management approach. Given the knowledge available at this time, I think everyone would agree that both fetal alcohol exposure and radiation exposure are harmful. The question for both is how much is safe, and how much is harmful? With fetal alcohol exposure, Health Canada's message is clear: "If you are pregnant, or planning to become pregnant in the near future, do not drink alcohol. No amount or type of alcohol is considered safe." Yet, in the face of mounting evidence that WI-FI exposure in children may not be safe in the previously accepted "dosage", Health Canada does not see fit to adopt the same cautious approach, and in fact, supports exposing our kids to even more microwave radiation than ever before.

The Precautionary Principle is, in the words of Health Canada's Beth Pieterson, "a public policy approach for risk management of possible, but unproven, adverse health effects". It should be invoked "when there is only some evidence, and it's not conclusive" that something is harmful. The Precautionary Principle was the reason for bisphenol A plastic being pulled from store shelves a few years back.

Well in fact, there is evidence that WI-FI exposure is harmful. True, some of it is anecdotal, and there is evidence supporting both sides of the argument, but there is an increasing body of published scientific evidence that suggests there is cause for concern regarding WI-FI exposure. This would seem to fit the criteria for the Precautionary Principle, yet strangely, Health Canada has still not seen fit to invoke it.

Health Canada has shown itself to be extremely slow to change its stance, even in the face of mounting evidence. As an example, at this time, Health Canada still approves the use of many pesticides that many communities have collectively decided to discontinue.

There are many conflicts of interest that exist within Health Canada and other government health agencies, with wireless industry affiliated people making “safety” decisions for Canadian citizens. I urge you to undertake true consultation with scientific and medical experts working in the field who are not affiliated with any industry or government organizations. I realize and respect that you are a busy person and that proper investigation with due diligence is a time-consuming and daunting task. In that, I would be more than happy to provide you with links to valid and impartial scientific publications, along with those scientist’s academics and employment positions, as well as evidence and statements of the afore-mentioned suppression of scientific findings and conflicts of interest.

My second major area of concern surrounds the issue of informed consent. There is a major difference between an exposure that an individual chooses to accept and one that is forced on an individual who can do nothing about it, especially a child. Parents have a fundamental right to choose, in light of a well-known controversy, what environmental toxins his child is exposed to, within reason. Limiting their child’s exposure to WI-FI, which is a recognized 2b carcinogenic, is well within reason. Compulsory and involuntary exposure to both WI-FI and personal wireless devices in a public educational environment where children are captive, is a violation of both children’s and parent’s rights and a violation of district policy 406.1.2 which states: “At no time will the use of any personal electronic device invade or infringe upon the privacy or safety of any member of the school district community.”

I have worked in the field of health care for many years, and I quite literally cannot get a patient out of bed without their informed consent. A technician most certainly could not do a CAT scan on a patient without their informed consent, nor could a surgeon perform surgery (and please note that "informed" means that the patient must be informed of the benefits and the risks associated with that particular test/procedure/therapy). Similarly, I think most people would agree that no one has the right to expose non-smokers to second hand cigarette smoke without the non-smoker's consent, because of the health risks involved. Why does that same need for consent not apply to WI-FI exposure? I find it curious that the school/school board cannot publish my child's picture, cannot teach them sex ed., cannot take them on a field trip without my consent.... yet the board appears to feel that it has the right to expose my children to pulsed microwave radiation without my consent.

The Nuremburg Code of 1947 was designed to guide researchers by determining some ethical guidelines. One might argue that it does not apply in this case, as we are not talking about official "research"; but I maintain that it does, as the use of WI-FI in schools, with no previous research to support its safety in this context, is in fact an experiment. In 2008, the European Parliament wrote to its 27 countries urging them to ignore WHO guidelines and set exposure limits at lower levels. In response, the WHO (which only began studying microwave radiation effects on children in 2009) stated they will not comment on microwave radiation effects on people until 2015, when it will be able to establish effects on human beings.

The Nuremburg Code states, among many other things, that voluntary consent of the research subject is essential, and that the subject must be informed of any potential risks associated with the research. Yet parents have not been informed, and my right to deny consent for my children to be exposed to wireless radiation is not being considered, despite the words of Health Canada's Beth Pieterson: “I think parents have to make decisions all the time about the safety of their kids and the well-being of their families. I think they have to seek good information, talk to their health care providers, and get information from all sources. Science isn't black and white. There are always going to be different sides. They need to make their own decisions."

The fact of the matter is, that installing WI-FI in schools and allowing the regular and widespread use of personal wireless devices by students and then watching to see what happens to our children IS an experiment, one for which I do not consent to the use of my child.

My third major area of concern is around the issue of information. The school district has not been forthcoming with either their plans to install WI-FI, nor with any information to educate parents about the potential risks. I have received numerous notices home about the switch to reverse lunch hours, the change in bell times, FSA testing, and most recently, the change in report cards since the teachers’ strike. None of these posed any potential risk to the health of my children, yet the school and the school board extended quite an effort to keep me informed. In contrast, I have not seen any information sent home by the school board regarding either the installation or use of WI-FI, or any of the question marks or concerns surrounding its safety.

In fact from what I have seen, when questioned about WI-FI, the school board tries to convey the message that it is entirely in Health Canada’s hands to decide and that the school board has little to do with it. I find this deceiving and unethical, and it certainly appears to me that the school board is trying to put one over on the public. Parents are not protesting this technology plan because quite simply, the vast majority of them know little about it.

My fourth and final area of concern is that there is quite literally no need to install WI-FI in the schools, particularly given the Oct. 2011 cell phone advisory. Firstly, there is no need to provide wireless internet for personal devices because the use of them by children has been advised against by the agency you claim to follow. Secondly, despite the potential risks to their health, WI-FI will not allow children to access technology at school that they cannot do with safe, hardwired computers.

WI-FI is not mandatory or essential in any sense, it is voluntary. It is a proprietary choice, and those educators that are charged with a duty of care to provide a safe, toxin-free learning environment have the obligation to uphold that duty and make informed, unbiased decisions that prioritize the health and well-being of the children in their care. Have we really reached the point where unnecessary technology and exciting “partnerships” take precedence over children’s very lives?

I have heard the arguments that “radiofrequency radiation is all around us, so it is silly to think that WI-FI in the schools would make any significant difference to my child’s health.” That argument is akin to saying that because there is air pollution all around us, I might as well smoke. Or that since a person is overweight he/she may as well order the large platter of wings. Just because there are hazards and threats to my child’s health that I cannot control does not mean that I should passively accept those that I can control. I can control her exposure to microwave radiation. I do so in my home, and I am asking you to help me do so in her school environment, by removing WI-FI until we know more about the long-term safety of the technology and can prove, without a doubt, that exposure to this technology is indeed safe.
Just because we can install WI-FI does not mean that we should. Schools and public buildings in this country and others are now removing WI-FI because of health concerns. Can we not learn from their mistakes, rather than repeat them?

There are simply too many question marks around the safety of WI-FI and much new scientific evidence that must be considered in order to prevent a situation of negligence. Without concrete evidence of its safety I strongly feel that we must, for the sake of our children, proceed with extreme caution, rather than pursuing "progress" at any cost.

Dr. Sullivan I look forward to your response as soon as possible, outlining how you plan to address this issue with parents. When controversial, untested and potentially harmful technologies are utilized to deliver education and these tools are not mandated by any educational or health agency, the responsibility to address concerns and provide accountability lies with the person who chooses to utilize the technology - not the health agencies.

A Parent (name removed)

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