Power Line
Task Force
2 Sunfish
Lane
Sunfish
Lake, MN 55118
December 22, 2000
Jan K. Malcolm
Commissioner
Minnesota Department of Health
P.O. Box 64975
St. Paul, MN, 55164-0975
Dear Commissioner Malcolm,
Thank you for your letter of November 28, 2000 providing clarification of the Minnesota Department of Health’s position with regard to electric and magnetic fields (the “Assessment”).
The Power Line Task Force (PLTF) questioned the Department’s position in connection with Xcel’s proposed replacement SE Metro Line. The PLTF maintains without refutation that both the proposed and the present line pass closer to homes than any other line in the country. According to Xcel’s data, those who live adjacent to the line are radiated by up to 80 milligauss of magnetic fields, which is 160 times the 0.5 mG average exposure reported by the National Institute of Health in its EMFRapid study.
As we discuss below, the scientific consensus regarding the relationship between power line EMF and cancer has changed even since your Assessment was written. Whereas, when the Assessment was first written, there was some doubt on whether there was a statistically significant relationship, we shall show that there is now a strong consensus that those subject to high levels of EMF are at heightened risk for cancer. This change has occurred in substantial part because, as we will also show, the authors of the major studies that had previously found no relationship—studies upon which you based your findings—have now reworked their data and agree that their own studies do show a significant relationship.
In your September 1999 letter to the EQB, you expressed concern over the high EMF dosages experience by those living next to the SE Metro line. You expressed this concern regarding the decision on whether an Environmental Impact Statement should be ordered. In your recent letter, you appropriately delineate your earlier comments as referring to the context in which they were made. If the context remains essentially the same, presumptively your concerns are still relevant
After the EQB decided not to order an EIS, this issue was brought to the impacted cities, which formed a Steering Committee to address essentially this same issue. It appears, therefore, that your original expression of concern continues to be applicable, given that the concerns raised and the questions to be answered are the same now as they were at the EQB hearing.
The Assessment states, “There is no conclusive evidence [that] shows that exposures to residential electric and magnetic fields produce cancer or any other adverse human health effects.”[emphasis added]
The Power Line Task Force believes research confirms the Assessment’s conclusion to be correct with respect to residential EMF fields, which average, according to the NIEHS, about 0.5 mG.
Unfortunately, the Assessment fails to discriminate between residential levels of EMF and the high dosage levels experienced by those who live next to the SE Metro line. The Assessment is incorrect with respect to the much higher emissions of such non-residential sources of EMF as power lines.
With respect to high-dosage levels of EMF, the Assessment’s conclusion conflicts with the consensus of the scientific community. We enclose the relevant pages from the September/October 2000 issue of Microwave News. This 20-year-old newsletter has a reputation of being authoritative and unbiased.
On its first page, the Microwave News reports:
A consensus is emerging on EMF’s and childhood leukemia that is nothing short of remarkable. Not long ago many people, including well-informed researchers, would have characterized the existing epidemiological studies as a muddle—some finding a health risk, others finding nothing at all. But when the data are pulled together, a different picture emerges: a clear and consistent pattern of significant risks for average exposures above 4 mG.
You wouldn’t know it from the mass media, but the evidence for an association between magnetic field exposure and childhood leukemia is now stronger than ever. In particular, it is far stronger than it was in the early 1990s when newspapers covered the story on the front page.
Accordingly, with respect to higher levels of EMF, The Assessment appears to be inconsistent with the consensus among well-informed researchers.
Analysis of the Assessment
With respect to power lines, the Assessment is, as we shall demonstrate, seriously outdated by research published since it was written.
The body of the Assessment relies principally upon two research reviews and an old comment by the American Physical Society. The comment was made in 1995 and is therefore not informed by the substantial subsequent research.
The first research review cited by the Assessment is the 1997 report on residential electric fields conducted the National Research Council. Although the conclusions are properly reported, they are not properly interpreted. The NRC did in fact find a relationship between wire codes and cancer. In short, the NRC concluded that those who live near large wires appeared to contract more cancer than those who did not. For those who live near the ultimate in large wires, transmission power lines, this is a legitimate concern.
More fundamentally, however, the NRC data have been reworked, as discussed below, thereby invalidating both the report’s conclusions and the findings cited in the Assessment.
The other research review was contained in the 1999 NIEHS EMFRapid report. Here, the Assessment commits an egregious error with respect to power lines. It cherry picks the report by reproducing paragraphs favorable to the Assessment’s conclusions, while ignoring the report’s specific recommendation regarding power lines[1].
The EMFRapid report’s “Recommended Action” regarding power lines is as follows:
NIEHS suggests that the power industry continue its current practice of siting power lines to reduce exposures….
Any discussion of the EMFRapid report with respect to power lines that omits an analysis of the NIEHS specific recommendation on these lines is pejoratively incomplete. If the NIEHS really believed there was no danger, as the Assessment suggests, why would it recommend that power lines be sited so as to reduce exposures? At a minimum, this should have been addressed by the Assessment.
In citing the findings of research reviews, the Assessment omits a key review. In 1998, the NIEHS convened a Working Group to review the dangers of EMF in the context of standards of the International Agency for Cancer Research. The IARC is part of the World Health Organization. The panel met in Brooklyn Park, MN. By a substantial majority, this panel characterized EMF as a Group 2B, “Possible Carcinogen.” According to the IARC, this is defined as: “The exposure circumstance entails exposures that are possibly carcinogenic to humans.” More information on this panel and its findings is available on the NIEHS web site at http://www.niehs.nih.gov/emfrapid/html/WGReport/WorkingGroup.html.
In summary, of the three citations examined in the Assessment, one is outdated, one is superceded by subsequent research, and the findings of the third are improperly characterized. In addition, a key relevant review was omitted from the analysis.
In an Appendix, the Assessment addresses four studies published in 1999. Three of these find a relationship between EMF and cancer. The fourth study, attributed to “Day et al,” is discussed below.
New
Research
EMF’s impact upon the human body is an active field of research. Even since our last letter to the department, there has been important additional published research.
A breakthrough analysis appears the September issue of the British Journal of Cancer (vol. 83, pp. 692-698). It pools raw data from nine different EMF studies. It found average childhood exposure to 4mG or more doubled the chance of developing leukemia. All the children living adjacent to the SE Metro line receive exposures well in excess of 4 mG. According to the study’s authors, “The level of [statistical] significance that we see for the excess risk at high exposure makes chance an unlikely explanation.”
A second, similar, analysis by Dr. Sander Greenland of UCLA appears in the November issue of Epidemiology. The Greenland analysis incorporates data from 15 studies. It also finds a reworking of the studies’ data reveals a strong relationship between EMF and cancer.
These analyses bear importantly upon the Assessment for several reasons. Among the research incorporated into both the British Journal and the Greenland analyses is the very NRC study cited by the Assessment. In short, whereas the Assessment cites the NRC research as supporting the benign EMF view, new information suggests that the data in the NRC research support exactly the opposite conclusion: i.e., EMF above 4mG is carcinogenic.
The British Journal analysis is particularly relevant to the Assessment. Your letter invited us to contact the Assessment’s authors, Chuck Stroebel. We did so. He told us that Dr. Leslie Robinson of the University of Minnesota reviewed the Assessment’s conclusions. According to Mr. Stroebel, Dr. Robinson’s association with the author of the NRC study, Dr. Martha Linet, enhances his credentials.[2] Dr. Linet is a coauthor of the British Journal Study and directed its US-based analysis.[3] It would appear, therefore, that, from the Assessment’s perspective, the British Journal study must be determinative.
As noted above, the Assessment refers in its Appendix to a study conducted by “Day et al.” The reference here is to a study headed by Nicholas Day for the UK Childhood Cancer Study, published in the Lancet in 1999. The Assessment characterizes the UKCCS study has supporting the benign EMF hypothesis.
One of the co-authors of the British Journal of Cancer analysis is the selfsame Nicholas Day, and the data used for the UKCCS study was included in the British Journal database[4]. The results of the British Journal study completely reverse the findings of the original study as summarized in the Appendix to the Assessment.[5] Upon reanalysis, the UKCCS data now are seen as supporting the conclusion that EMF levels above 4mG are carcinogenic. Therefore, after the incorporation of the British Journal analysis, all four studies cited in the Appendix now point to a relationship between EMF’s and cancer!
In short, with respect to the levels of EMF experienced by those who live near the SE Metro Line, all but one of the references in the Assessment either find a relationship between EMF and cancer or urge that lines be sited so as to reduce exposure. The remaining reference was developed 6 years ago, a period before the emergence of what Microwave News characterizes as “a clear and consistent pattern of significant risks for average exposures above 4 mG.”
Since all but one of the citations in the Assessment are now seen as suggesting a positive relationship between EMF and cancer, and since that is now the view of the informed scientific community, the original findings of the Assessment are clearly no longer valid.
Public Policy Standards
The same issue of Microwave News cites a new study that buttresses the conclusion of the study listed in my previous letter that EMF’s may enhance the chances for heart disease. In your letter, you dismissed the original study on the basis that it provides “only limited, if any, support to demonstrate” the heart disease thesis. The recent validation of the earlier research may resolve your doubts.
The Assessment erected a separate standard. In reviewing one study[6], the Assessment noted the absence of a dose-response relationship. The British Journal analysis meets that standard, reporting no relationship at low EMF doses and a statistically significant relationship at high doses.
We believe that Microwave News is correct in characterizing the relationship between EMF and cancer as “clear and consistent.” But even so, the concept of “limited” support of a health thesis raises an important public policy concern.[7] When should “limited” findings be translated into proactive government policy? Can government action be undertaken, as the Assessment suggests, only after the establishment of “conclusive” evidence? Is public policy frozen in the absence of a demonstration of both an ironclad epidemiological findings and a proven casual relationship?
The relevant standard is the “Precautionary Principle,” which was articulated as follows at the Racine, Wisconsin, 1998 Wingspread conference:
When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.
I.e., actions taken to protect the environment and human health take precedence. As one example, the application of this principle led the federal government to support the removal of genetically modified corn from the food distribution system, even though science cannot say definitely whether the consumption of such corn is dangerous.
This principle is well established in law. It is implicit in the 1958 Delaney Clause overseeing pesticide residues in food[8], and is a requirement for Environmental Impact Statements. It is incorporated in the UN Biosafety Protocol regarding trade in genetically modified products.
The Assessment ignores this rule. Rather, it explicitly requires absolute proof of a causal relationship. The mechanisms leading to most cancers are not well understood. That standard would be difficult to meet with most recognized carcinogens. The state of knowledge with respect to EMF is comparatively advanced, as cellular and DNA research is making giant steps in explaining why EMF causes cancer. (See, for example, the body of research produced by Columbia University’s Reba Goodman and Martin Blank.)
Further
Research
The Assessment notes the Department seeks more information on the current status of research on EMF. The Power Line Task Force stands ready to make available to the department the services of some of the leading active researchers in this field.
In addition, there exists an opportunity for the Department to efficiently obtain substantial high-level information on EMF. By coincidence, the annual meeting of the Bioelectromechanics Society will be held in St. Paul over Fathers Day, 2001. This is the leading research organization on EMF. Its annual meetings are often inaccessible as they are frequently held outside the US. The Department therefore may want to participate in this year’s meeting’s symposiums on advanced research on EMF. We would be glad to provide the Department more information on this meeting, or the Department may wish to refer to the Society’s website, http://www.bioelectricmechanics.org/.
Conclusion
Clearly, at the EQB, you were uncomfortable with the rigid application of the “absolute proof of a causal relationship” standard. You were correct. Hundreds of humans are exposed to the high EMF emitted by the SE Metro Line. Many of these are children, who we now know experience a resulting heightened risk of contracting leukemia.
Martha Linet, Nicholas Day, and Mary McBride and the other scientists involved with the British Journal research demonstrated commendable flexibility and integrity in acknowledging their earlier studies were wrong. You based your finding upon these studies. Accordingly, your conclusions as expressed in the Assessment are no longer valid. We hope and expect the Department now will harmonize its position with the new findings associated with these studies, thereby acknowledging that radiating people with high doses of power line EMF is no longer an acceptable health practice.
Sincerely,
Roger R. Conant, MGA, Ph.D., CLU
Spokesperson
cc: Chuck Stroebel, Dept. of Health
Michael Michaud, Department of Commerce
John Hines, Environmental Quality Board
Kate O’Connell, Department of Commerce
Janet Gonzales, Public Utilities Commission
Susan Heffron, Pollution Control Agency
[1] The citations in the Assessment appear to be drawn from consecutive paragraphs, but are, in fact, plucked from various sections of the report. The juxtaposition of the selected paragraphs creates an impression that the study is firmer in its findings than is in fact the case. As one example, the third cited paragraph in the Assessment implies that the NIEHS is utterly unconcerned about the dangers of EMF. This reading is incorrect because the citation omits the Report’s subsequent paragraph, which reads in part: “However, because virtually everyone in the United States uses electricity and therefore is routinely exposed to ELF-EMF, passive regulatory action is warranted such as a continued emphasis on educating both the public and the regulated community on means aimed at reducing exposures. ” [Emphasis added]
[2] In fact, Dr. Robinson is a co-author of the NRC study, and therefore is professionally identified with the benign EMF thesis.
[3] In spite of the fact she is a co-author, Dr. Linet is uncomfortable with the results of the British Journal study, which appear to contradict her own earlier findings. Microwave News reports that she suggests the findings may be attributable to selection bias in her own data. She is, therefore, accusing her own study of being subject to a newly discovered bias. Her co-authors do not agree.
[4] Indeed, the British Journal study was delayed specifically so that the UK Childhood Cancer study could be included in its database.
[5] On the subject of bias, Microwave Age quotes Day as saying “Bias and confounding may be the main factors in operation. [On the other hand] an excess was seen which is very unlikely to be due to chance, and is consistent with a causal role for EMF’s at these high levels. It cannot just be dismissed.” Sander Greenland, author of the similar Epidemiology report says: “It’s hard for me to see how selection bias would operate in the same way in all these cases.” .
[6] Characterized as Green (1999b).
[7] The Power Line Task Force’s spokesperson, Dr. Conant, received his Masters at Wharton in Public Policy before earning is PhD in economics from Columbia University.
[8] The Delaney clause mandated that a pesticide that demonstrated a cancer-causing potential at any dose level could not be used in food. It is granted by Xcel among others that EMF over 1000 mG causes cancer. The application of the Delaney clause to EMF from overhead transmission power lines would require their removal from urban areas.