C4ST Fact-checks Government of Canada Webpages Regarding Health Risks and Wireless Technologies, including 5G
(January 2021)

Currently, the Government of Canada (GoC) provides assurances on its webpages that exposures to radiofrequency (RF) energy (=radiation) from 5G technologies and from everyday wireless devices such as cell phones and cell tower antennas are safe.

Canadians for Safe Technology (C4ST) has fact-checked some of these statements and found them to be inaccurate and misleading to the point of being “misinformation.”

Note: when you click on a superscript number in the text, you will be taken to the relevant footnote at the bottom of the page. To return to your original position, simply click on the number.

Website says

#01. Safety Code 6 protects “those using 5G technologies.”

Truth is

These statements are inaccurate and misleading, for two reasons:. 

1) No long-term human or environmental safety testing of 5G technologies has been reported.

Health Canada is turning a blind eye to the science and deaf ear to the warnings of scientists, medical doctors and other experts that 5G technologies have not been tested for harmful biological effects. Full 5G rollout will require the installation of hundreds of thousands. 6, 7 C4ST’s position is that 5G rollout should be halted until scientists who are independent of industry influence demonstrate that 5G technologies are safe for Canadians. 8, 9

5G will use millimetre frequencies, in addition to many of the same frequencies already in use (2G, 3G,4G and LTE). The science on the effects of exposure to millimetre frequencies on biological systems is sparse. Most studies have looked at only one frequency in the millimetre range and not the complex RF mixtures that 5G technologies will emit.

Two recent literature reviews published in peer-reviewed journals analyzing the scientific evidence on the biological effects of 5G frequencies both concluded that there is not enough known about these 5G millimetre frequencies to assure safety.

• The review by Dr. Myrtill Simkó and Dr. Mats-Olof Mattson (2019) from Sweden identified 94 relevant studies, with 80% of the in vivo studies and 58% of the in vitro studies showing biological effects. They concluded, “The available studies do not provide adequate and sufficient information for a meaningful safety assessment.”10

• The review by Finnish researcher Dr. Darius Leszczynski (2020) on skin and skin cells concluded, “the scientific evidence concerning possible effects of millimeter-waves on humans is insufficient to devise science-based exposure limits and to develop science-based human health policies.”11

Furthermore, considering that many 5G technologies are still in development, Health Canada cannot possibly assure safety for biological effects of these complex technologies. Health Canada’s basis for its statement on safety is based only on temperature simulations.

2) Safety Code 6 (2015) is outdated. It does not protect the health of Canadians from RF radiation emitted by pre-5G technologies (cell phones, cell tower antennas, Wi-Fi, etc.).


Website says

#02. Safety Code 6 protects everyone exposed to radiofrequency EMF [electromagnetic fields].5

Truth is

These statements are inaccurate and misleading, for two reasons:. 

1) No long-term human or environmental safety testing of 5G technologies has been reported.

Health Canada is turning a blind eye to the science and deaf ear to the warnings of scientists, medical doctors and other experts that 5G technologies have not been tested for harmful biological effects. Full 5G rollout will require the installation of hundreds of thousands. 6, 7 C4ST’s position is that 5G rollout should be halted until scientists who are independent of industry influence demonstrate that 5G technologies are safe for Canadians. 8, 9

5G will use millimetre frequencies, in addition to many of the same frequencies already in use (2G, 3G,4G and LTE). The science on the effects of exposure to millimetre frequencies on biological systems is sparse. Most studies have looked at only one frequency in the millimetre range and not the complex RF mixtures that 5G technologies will emit.

Two recent literature reviews published in peer-reviewed journals analyzing the scientific evidence on the biological effects of 5G frequencies both concluded that there is not enough known about these 5G millimetre frequencies to assure safety.

• The review by Dr. Myrtill Simkó and Dr. Mats-Olof Mattson (2019) from Sweden identified 94 relevant studies, with 80% of the in vivo studies and 58% of the in vitro studies showing biological effects. They concluded, “The available studies do not provide adequate and sufficient information for a meaningful safety assessment.”10

• The review by Finnish researcher Dr. Darius Leszczynski (2020) on skin and skin cells concluded, “the scientific evidence concerning possible effects of millimeter-waves on humans is insufficient to devise science-based exposure limits and to develop science-based human health policies.”11

Furthermore, considering that many 5G technologies are still in development, Health Canada cannot possibly assure safety for biological effects of these complex technologies. Health Canada’s basis for its statement on safety is based only on temperature simulations.

2) Safety Code 6 (2015) is outdated. It does not protect the health of Canadians from RF radiation emitted by pre-5G technologies (cell phones, cell tower antennas, Wi-Fi, etc.).


Website says

#03. Based on the available scientific evidence, there are no health risks from exposures to the low levels of radiofrequency EMF [electromagnetic fields] emitted by cell phones and antenna installations.

Truth is

This is an inaccurate statement. There is indisputable evidence that there are serious health risks from exposure to radiofrequency EMF (RF radiation) at and below the maximum exposure limits in Safety Code 6 (2015).


Website says

#04. The scientific evidence does not support a link between exposure to radiofrequency EMF and cancer at the levels permitted by Canadian exposure guidelines.

Truth is

These are inaccurate and misleading statements. Experts maintain that a "known human carcinogen" classification is the appropriate classification. This is the same category as asbestos and cigarette smoke. Below are two high-quality published papers supporting our statement.

For more studies, see: http://c4st.org/wp-content/uploads/2020/05/Supplemental-Material-for-Suspend-5G-Canada-Appeal.pdf

1) The publication “Cancer epidemiology update, following the 2011 IARC evaluation of radiofrequency electromagnetic fields (Monograph 102)”12 states, “When considered with recent animal experimental evidence, the recent epidemiological studies strengthen and support the conclusion that RFR [RF Radiation] should be categorized as carcinogenic to humans (IARC Group 1).” Dr. Anthony Miller, lead author on this paper, a Canadian MD epidemiologist, has been awarded the Medal of Honour by the World Health Organization’s International Agency for Research on Cancer (IARC) and in 2019 was named a Member of the Order of Canada.

2) In “Comments on the US National Toxicology Program Technical Reports on Toxicology and Carcinogenesis Study in Rats Exposed to Whole-Body Radiofrequency Radiation at 900 MHz and in Mice Exposed to Whole-Body Radiofrequency Radiation at 1,900 MHz,” the authors conclude, “Based on the Preamble to the IARC Monographs, RF radiation should be classified as carcinogenic to humans, Group 1.”13 The research published by lead author Dr. Lennart Hardell and his team provided key evidence for IARC’s decision in 2011 to designate RF radiation as a Class 2B, “possible” human carcinogen.14

Radiofrequency radiation is slated to be re-evaluated by IARC. A recent IARC report (pages 148-149)15 summarizes more recent evidence, and states that the science is ready for evaluation and is a “high priority.”


Website says

#05. In 2011, the International Agency for Research on Cancer (IARC), which is part of the World Health Organization, classified radiofrequency electromagnetic fields as possibly carcinogenic to humans (Group 2B), based on an increased risk for glioma, a malignant type of brain cancer, associated with wireless phone use.

However, the vast majority of research to date does not support a link between RF energy exposure and cancers in humans.

Truth is

These are inaccurate and misleading statements. Experts maintain that a "known human carcinogen" classification is the appropriate classification. This is the same category as asbestos and cigarette smoke. Below are two high-quality published papers supporting our statement.

For more studies, see: http://c4st.org/wp-content/uploads/2020/05/Supplemental-Material-for-Suspend-5G-Canada-Appeal.pdf

1) The publication “Cancer epidemiology update, following the 2011 IARC evaluation of radiofrequency electromagnetic fields (Monograph 102)”12 states, “When considered with recent animal experimental evidence, the recent epidemiological studies strengthen and support the conclusion that RFR [RF Radiation] should be categorized as carcinogenic to humans (IARC Group 1).” Dr. Anthony Miller, lead author on this paper, a Canadian MD epidemiologist, has been awarded the Medal of Honour by the World Health Organization’s International Agency for Research on Cancer (IARC) and in 2019 was named a Member of the Order of Canada.

2) In “Comments on the US National Toxicology Program Technical Reports on Toxicology and Carcinogenesis Study in Rats Exposed to Whole-Body Radiofrequency Radiation at 900 MHz and in Mice Exposed to Whole-Body Radiofrequency Radiation at 1,900 MHz,” the authors conclude, “Based on the Preamble to the IARC Monographs, RF radiation should be classified as carcinogenic to humans, Group 1.”13 The research published by lead author Dr. Lennart Hardell and his team provided key evidence for IARC’s decision in 2011 to designate RF radiation as a Class 2B, “possible” human carcinogen.14

Radiofrequency radiation is slated to be re-evaluated by IARC. A recent IARC report (pages 148-149)15 summarizes more recent evidence, and states that the science is ready for evaluation and is a “high priority.”


Website says

#06. While there have been some studies reporting an increase in incidence of brain cancer among long-term, heavy cell phone users, other studies conducted in many countries around the world, including studies assessing brain cancer trends among large populations, do not find changes in brain cancer incidence. This is despite widespread use of cell phones over the past 25 years.. 

Truth is

These are misleading and inaccurate statements. Many studies and reports show increased brain cancer. C4ST is not suggesting that all increases are only caused by exposure to RF radiation; however, it must be considered as a substantial contributor, not dismissed:

  1. The incidence of neuro-epithelial brain cancers has significantly increased in all children, adolescent, and young adult age groups from birth to 24 years in the United States.16,17
  2. A sustained and statistically significant rise in glioblastoma multiforme across all ages has been described in the UK.18
  3. The incidence of several brain tumors is increasing at statistically significant rates, according to the 2010–2017 Central Brain Tumor Registry of the U.S. (CBTRUS) dataset.19
    • There was a significant increase in incidence of radiographically diagnosed tumors of the pituitary from 2006 to 2012.20
    • Meningioma rates have increased in all age groups from 15 through 85+ years.
    • Nerve sheath tumor (Schwannoma) rates have increased in all age groups from age 20 through 84 years.
    • Vestibular Schwannoma rates, as a percentage of nerve sheath tumors, have also increased from 58% in 2004 to 95% in 2014.
  4. Canadian data indicates a doubled risk of a rare brain cancer for those with more than 558 lifetime hours’ use of a cell phone.21 (Over 20 years, that would be less than 5 minutes per day.)
  5. A multicenter case-control study in France concluded, “These additional data support previous findings concerning a possible association between heavy mobile phone use and brain tumours”.22
  6. A 2020 review and meta-analysis has found “evidence that linked cellular phone use to increased tumor risk.”23
  7. A just published study on thyroid cancers in Nordic countries24 concluded, “These results are in agreement with recent results on increased thyroid cancer risk associated with the use of mobile phones ....”
Furthermore, a 2020 review and meta-analysis found that RF radiation exposure “significantly increased risk of breast cancer.”25 The Government of Canada webpages state that “the vast majority of research to date does not support a link between RF energy and cancers in humans.” As any reliable scientist will tell you, science is not like a hockey game where the most points win. The quality of the studies is key, and rigorous methods are used to grade quality and to pool results. When high-quality studies show harm, as in this case, then this must be addressed. The risks of cancer and exposure to RF energy (=radiation) are affecting Canadians today, and the sooner Health Canada acknowledges this and revises Safety Code 6, the sooner the health of Canadians will be adequately protected.


Website says

#07. The Safety Code 6 limits for human exposure to RF energy are designed to provide protection for all age groups, including children, on a continuous (24 hours a day/seven days a week) basis.

Truth is

Children are not little adults.

All of the “safety” information in Safety Code 6 is based on “models,” not real children. The modelling for cell phone safety is based on a 200-pound (91 kg) mannequin and tests only for temperature changes30 —not for any of the biological effects such as DNA damage. A study showing RF radiation penetrates into deeper brain structures in children than in adults was conducted by Dr. Claudio Fernandez et al. (2018).31 Dr. Tom Butler has summarized some of the studies about why children’s health is of particular concern.32


Website says

#08. There have been thousands of scientific studies carried out to evaluate the safety of radiofrequency EMF. In fact, the evidence from these studies establishes two adverse health effects that can occur at levels above the Canadian limits:

  • tissue heating (such as the warming of your skin)
  • nerve stimulation (which can cause a tingling sensation in your skin)

Truth is

The thousands of studies referenced above also include high-quality studies that show adverse health effects at or below Canadian limits. Ambient and commonly encountered levels of RF radiation are scientifically demonstrated to cause or contribute to cancers,36,37,38,39 sperm damage,40 reproductive harms,41 learning and memory deficits,42 and neurodegenerative, cellular and genetic damage.43,44,45,46,47,48

If the evidence is so strong that the only adverse effects are heating and nerve stimulation, then this information should be available to the public, e.g., on GoC webpages.

The relationship between tissue heating and harm from RF radiation was first proposed in the 1920s.49 There is substantial evidence that heating due to exposures exceeding the limit for temperature rise in Safety Code 6 is not a threshold for harm to tissues.

The nerve stimulation reported by Health Canada in Safety Code 6 relates to the lowest part of the RF range which is not presently in widespread use for wireless communications. Therefore, the general public does not experience much exposure to these frequencies.

A growing number of RF radiation exposed Canadians experience immediate and debilitating health problems (that could be prevented) such as headaches, irregular heartbeats, cognitive difficulties and insomnia, resulting in poor quality of life.50 All Canadians are susceptible to developing such health issues, unless their ever-increasing exposure to RF radiation is curtailed.


Website says

#09. Health Canada scientists consider all peer-reviewed scientific studies and consider many different potential health effects including thermal, non-thermal and biological effects.

Truth is

These are misleading statements. When Health Canada says it has “considered” studies, this seems to mean it may have looked at them but disregarded the results—general statements are made but no specific reasons for rejection provided. Health Canada has never published a systematic review that meets international standards51 of transparent searching, data extraction, scientific synthesis and weighing of the evidence, nor a risk assessment based on measured and projected exposures, nor even a list of which studies it has considered.

It seems the most Health Canada is willing to do is provide links to other agencies or organizations that also rely on the premise from the 1920s52 that RF exposures cannot harm if there is no excessive heating of tissue within 6 minutes.

Health Canada provides no definition of “consider” or “considered.” Although hundreds of high-quality studies show harm below maximum exposure limits (that, according to Health Canada, should be safe), none of these studies and none of their results have been incorporated into Safety Code 6.

Well over 200 peer-reviewed studies53 published since the last revision of Safety Code 6 (2015) describe harmful effects of (RF) radiation on human health below Safety Code 6 limits. These 200 studies are discussed in the CBC Marketplace episode “The Secret Inside Your Cellphone.”54

In 2015, during Parliamentary health committee hearings, Health Canada was asked to provide its rationale for ignoring the science in 140 studies omitted55 from both the Royal Society of Canada’s review and its own. The entire response (Appendix A) lacked any details. The Rationale document that Health Canada used to justify the changes (and lack of changes) did not mention these studies.56 A summary of the omitted studies is in Appendix B.

The published paper “Risks to Health and Well-Being From Radio-Frequency Radiation Emitted by Cell Phones and Other Wireless Devices”57 summarizes the strong evidence that there are health effects from exposures to low levels of RF radiation, below Safety Code 6 maximum limits. Furthermore, a systematic review and meta-analysis published in 2020 also supports that there are tumor risks with prolonged exposure to cell phone emissions.58

When new information becomes available, the proper scientific approach is to study and analyze the results to ensure a current premise is still correct. Health Canada appears to take the opposite approach and look for ways to dismiss any new evidence that challenges its underlying assumptions of Safety Code 6. In this case, Health Canada shows complete disregard for the $30 million US National Toxicology Program study with more than 2,000 rodents that showed clear evidence of cancer and DNA damage—despite the fact that this study passed through peer-review three times before publication.

Currently there are two main schools of thought among scientists and other experts who work in this field. There is a high degree of consensus within each group but not between the groups.

One group, including Health Canada and many scientists funded by the technology industry, remains firmly entrenched in the one hundred year old paradigm59 that radiofrequency/ microwave radiation must heat to cause harm, and clings to this 1920s assumption to support the current (inadequate) guidelines.

Safety Code 6 was first published in 1979 and was based on the premise that if RF energy (=radiation) did not heat, it would not harm living tissue. Since then, Safety Code 6 limits have remained based on temperature change considerations.

The other group, consisting mainly of those who conduct work independent of industry influence, maintains that harm can occur at non-heating (non-thermal) levels. The findings in research published by these scientists and physicians demonstrate mechanisms and adverse outcomes from RF radiation exposures at low levels of exposure. Many of these experts treat and educate people to regain their health. Health Canada and other “authoritative bodies” and agencies in countries noted in the GoC webpages dismiss the findings in these studies.

Health Canada states that it will not take action before evidence is generally accepted by the broader scientific community. The broader scientific community, including those with vested interests, is obviously deeply divided on this issue. See more on this in Section 3.3. Just as with historical contested science on health effects of lead, asbestos, smoking, persistent organic pollutants and other concerns, a consensus may not be reached in the near future.

Questions are: on which side of history the Government of Canada will rest; how long it takes to learn “Late Lessons from Early Warnings.”60

Given the enormous implications for public health and the strong science indicating health risks, it makes common sense to take precautionary measures. One action would be to post cautions on the GoC websites regarding health risks of wireless technology (such as cell phones, baby monitors and other wireless RF emitting devices) and to halt wireless 5G rollout (focusing on fibre to the premises, FTTP) until public health safety can be assured.61


Website says

#10. Canadians are protected from the cumulative effects of RF energy when Safety Code 6 is respected.

Truth is

These are misleading statements. When Health Canada says it has “considered” studies, this seems to mean it may have looked at them but disregarded the results—general statements are made but no specific reasons for rejection provided. Health Canada has never published a systematic review that meets international standards of transparent searching, data extraction, scientific synthesis and weighing of the evidence, nor a risk assessment based on measured and projected exposures, nor even a list of which studies it has considered.

It seems the most Health Canada is willing to do is provide links to other agencies or organizations that also rely on the premise from the 1920s that RF exposures cannot harm if there is no excessive heating of tissue within 6 minutes.

Health Canada provides no definition of “consider” or “considered.” Although hundreds of high-quality studies show harm below maximum exposure limits (that, according to Health Canada, should be safe), none of these studies and none of their results have been incorporated into Safety Code 6.

Well over 200 peer-reviewed studies published since the last revision of Safety Code 6 (2015) describe harmful effects of (RF) radiation on human health below Safety Code 6 limits. These 200 studies are discussed in the CBC Marketplace episode “The Secret Inside Your Cellphone.”

In 2015, during Parliamentary health committee hearings, Health Canada was asked to provide its rationale for ignoring the science in 140 studies omitted from both the Royal Society of Canada’s review and its own. The entire response (Appendix A) lacked any details. The Rationale document that Health Canada used to justify the changes (and lack of changes) did not mention these studies. A summary of the omitted studies is in Appendix B.

The published paper “Risks to Health and Well-Being From Radio-Frequency Radiation Emitted by Cell Phones and Other Wireless Devices” summarizes the strong evidence that there are health effects from exposures to low levels of RF radiation, below Safety Code 6 maximum limits. Furthermore, a systematic review and meta-analysis published in 2020 also supports that there are tumor risks with prolonged exposure to cell phone emissions.

When new information becomes available, the proper scientific approach is to study and analyze the results to ensure a current premise is still correct. Health Canada appears to take the opposite approach and look for ways to dismiss any new evidence that challenges its underlying assumptions of Safety Code 6. In this case, Health Canada shows complete disregard for the $30 million US National Toxicology Program study with more than 2,000 rodents that showed clear evidence of cancer and DNA damage—despite the fact that this study passed through peer-review three times before publication.

Currently there are two main schools of thought among scientists and other experts who work in this field. There is a high degree of consensus within each group but not between the groups.

One group, including Health Canada and many scientists funded by the technology industry, remains firmly entrenched in the one hundred year old paradigm that radiofrequency/ microwave radiation must heat to cause harm, and clings to this 1920s assumption to support the current (inadequate) guidelines.

Safety Code 6 was first published in 1979 and was based on the premise that if RF energy (=radiation) did not heat, it would not harm living tissue. Since then, Safety Code 6 limits have remained based on temperature change considerations.

The other group, consisting mainly of those who conduct work independent of industry influence, maintains that harm can occur at non-heating (non-thermal) levels. The findings in research published by these scientists and physicians demonstrate mechanisms and adverse outcomes from RF radiation exposures at low levels of exposure. Many of these experts treat and educate people to regain their health. Health Canada and other “authoritative bodies” and agencies in countries noted in the GoC webpages dismiss the findings in these studies.

Health Canada states that it will not take action before evidence is generally accepted by the broader scientific community. The broader scientific community, including those with vested interests, is obviously deeply divided on this issue. See more on this in Section 3.3. Just as with historical contested science on health effects of lead, asbestos, smoking, persistent organic pollutants and other concerns, a consensus may not be reached in the near future.

Questions are: on which side of history the Government of Canada will rest; how long it takes to learn “Late Lessons from Early Warnings.”

Given the enormous implications for public health and the strong science indicating health risks, it makes common sense to take precautionary measures. One action would be to post cautions on the GoC websites regarding health risks of wireless technology (such as cell phones, baby monitors and other wireless RF emitting devices) and to halt wireless 5G rollout (focusing on fibre to the premises, FTTP) until public health safety can be assured.


Website says

#11. Health Canada continues to monitor all domestic and international scientific evidence on radiofrequency EMF and health. Should new scientific evidence emerge to demonstrate that exposure to radiofrequency EMF at levels below the Canadian limits is a health concern, the Government of Canada would take action to protect the health and safety of Canadians.

Truth is

These are misleading statements. When Health Canada says it has “considered” studies, this seems to mean it may have looked at them but disregarded the results—general statements are made but no specific reasons for rejection provided. Health Canada has never published a systematic review that meets international standards of transparent searching, data extraction, scientific synthesis and weighing of the evidence, nor a risk assessment based on measured and projected exposures, nor even a list of which studies it has considered.

It seems the most Health Canada is willing to do is provide links to other agencies or organizations that also rely on the premise from the 1920s that RF exposures cannot harm if there is no excessive heating of tissue within 6 minutes.

Health Canada provides no definition of “consider” or “considered.” Although hundreds of high-quality studies show harm below maximum exposure limits (that, according to Health Canada, should be safe), none of these studies and none of their results have been incorporated into Safety Code 6.

Well over 200 peer-reviewed studies published since the last revision of Safety Code 6 (2015) describe harmful effects of (RF) radiation on human health below Safety Code 6 limits. These 200 studies are discussed in the CBC Marketplace episode “The Secret Inside Your Cellphone.”

In 2015, during Parliamentary health committee hearings, Health Canada was asked to provide its rationale for ignoring the science in 140 studies omitted from both the Royal Society of Canada’s review and its own. The entire response (Appendix A) lacked any details. The Rationale document that Health Canada used to justify the changes (and lack of changes) did not mention these studies. A summary of the omitted studies is in Appendix B.

The published paper “Risks to Health and Well-Being From Radio-Frequency Radiation Emitted by Cell Phones and Other Wireless Devices” summarizes the strong evidence that there are health effects from exposures to low levels of RF radiation, below Safety Code 6 maximum limits. Furthermore, a systematic review and meta-analysis published in 2020 also supports that there are tumor risks with prolonged exposure to cell phone emissions.

When new information becomes available, the proper scientific approach is to study and analyze the results to ensure a current premise is still correct. Health Canada appears to take the opposite approach and look for ways to dismiss any new evidence that challenges its underlying assumptions of Safety Code 6. In this case, Health Canada shows complete disregard for the $30 million US National Toxicology Program study with more than 2,000 rodents that showed clear evidence of cancer and DNA damage—despite the fact that this study passed through peer-review three times before publication.

Currently there are two main schools of thought among scientists and other experts who work in this field. There is a high degree of consensus within each group but not between the groups.

One group, including Health Canada and many scientists funded by the technology industry, remains firmly entrenched in the one hundred year old paradigm that radiofrequency/ microwave radiation must heat to cause harm, and clings to this 1920s assumption to support the current (inadequate) guidelines.

Safety Code 6 was first published in 1979 and was based on the premise that if RF energy (=radiation) did not heat, it would not harm living tissue. Since then, Safety Code 6 limits have remained based on temperature change considerations.

The other group, consisting mainly of those who conduct work independent of industry influence, maintains that harm can occur at non-heating (non-thermal) levels. The findings in research published by these scientists and physicians demonstrate mechanisms and adverse outcomes from RF radiation exposures at low levels of exposure. Many of these experts treat and educate people to regain their health. Health Canada and other “authoritative bodies” and agencies in countries noted in the GoC webpages dismiss the findings in these studies.

Health Canada states that it will not take action before evidence is generally accepted by the broader scientific community. The broader scientific community, including those with vested interests, is obviously deeply divided on this issue. See more on this in Section 3.3. Just as with historical contested science on health effects of lead, asbestos, smoking, persistent organic pollutants and other concerns, a consensus may not be reached in the near future.

Questions are: on which side of history the Government of Canada will rest; how long it takes to learn “Late Lessons from Early Warnings.”

Given the enormous implications for public health and the strong science indicating health risks, it makes common sense to take precautionary measures. One action would be to post cautions on the GoC websites regarding health risks of wireless technology (such as cell phones, baby monitors and other wireless RF emitting devices) and to halt wireless 5G rollout (focusing on fibre to the premises, FTTP) until public health safety can be assured.


Website says

#12. When developing the exposure limits in Safety Code 6, Health Canada scientists consider all peer-reviewed scientific studies and employ a weight-of-evidence approach.

There are criteria that scientists use in order to establish scientific evidence for the existence of an adverse health effect. The evidence needs to be reproducible to ensure the results were not random or due to other factors. The evidence needs to be consistent across studies; for example, the evidence is stronger if different types of studies (epidemiology and laboratory) point to the same conclusion. The evidence needs to be evaluated in its totality, meaning that both positive and negative results are evaluated on their own merit and then evaluated as a whole. Finally, the evidence needs to be generally accepted by the broader scientific community.

Truth is

These are misleading statements. When Health Canada says it has “considered” studies, this seems to mean it may have looked at them but disregarded the results—general statements are made but no specific reasons for rejection provided. Health Canada has never published a systematic review that meets international standards of transparent searching, data extraction, scientific synthesis and weighing of the evidence, nor a risk assessment based on measured and projected exposures, nor even a list of which studies it has considered.

It seems the most Health Canada is willing to do is provide links to other agencies or organizations that also rely on the premise from the 1920s that RF exposures cannot harm if there is no excessive heating of tissue within 6 minutes.

Health Canada provides no definition of “consider” or “considered.” Although hundreds of high-quality studies show harm below maximum exposure limits (that, according to Health Canada, should be safe), none of these studies and none of their results have been incorporated into Safety Code 6.

Well over 200 peer-reviewed studies published since the last revision of Safety Code 6 (2015) describe harmful effects of (RF) radiation on human health below Safety Code 6 limits. These 200 studies are discussed in the CBC Marketplace episode “The Secret Inside Your Cellphone.”

In 2015, during Parliamentary health committee hearings, Health Canada was asked to provide its rationale for ignoring the science in 140 studies omitted from both the Royal Society of Canada’s review and its own. The entire response (Appendix A) lacked any details. The Rationale document that Health Canada used to justify the changes (and lack of changes) did not mention these studies. A summary of the omitted studies is in Appendix B.

The published paper “Risks to Health and Well-Being From Radio-Frequency Radiation Emitted by Cell Phones and Other Wireless Devices” summarizes the strong evidence that there are health effects from exposures to low levels of RF radiation, below Safety Code 6 maximum limits. Furthermore, a systematic review and meta-analysis published in 2020 also supports that there are tumor risks with prolonged exposure to cell phone emissions.

When new information becomes available, the proper scientific approach is to study and analyze the results to ensure a current premise is still correct. Health Canada appears to take the opposite approach and look for ways to dismiss any new evidence that challenges its underlying assumptions of Safety Code 6. In this case, Health Canada shows complete disregard for the $30 million US National Toxicology Program study with more than 2,000 rodents that showed clear evidence of cancer and DNA damage—despite the fact that this study passed through peer-review three times before publication.

Currently there are two main schools of thought among scientists and other experts who work in this field. There is a high degree of consensus within each group but not between the groups.

One group, including Health Canada and many scientists funded by the technology industry, remains firmly entrenched in the one hundred year old paradigm that radiofrequency/ microwave radiation must heat to cause harm, and clings to this 1920s assumption to support the current (inadequate) guidelines.

Safety Code 6 was first published in 1979 and was based on the premise that if RF energy (=radiation) did not heat, it would not harm living tissue. Since then, Safety Code 6 limits have remained based on temperature change considerations.

The other group, consisting mainly of those who conduct work independent of industry influence, maintains that harm can occur at non-heating (non-thermal) levels. The findings in research published by these scientists and physicians demonstrate mechanisms and adverse outcomes from RF radiation exposures at low levels of exposure. Many of these experts treat and educate people to regain their health. Health Canada and other “authoritative bodies” and agencies in countries noted in the GoC webpages dismiss the findings in these studies.

Health Canada states that it will not take action before evidence is generally accepted by the broader scientific community. The broader scientific community, including those with vested interests, is obviously deeply divided on this issue. See more on this in Section 3.3. Just as with historical contested science on health effects of lead, asbestos, smoking, persistent organic pollutants and other concerns, a consensus may not be reached in the near future.

Questions are: on which side of history the Government of Canada will rest; how long it takes to learn “Late Lessons from Early Warnings.”

Given the enormous implications for public health and the strong science indicating health risks, it makes common sense to take precautionary measures. One action would be to post cautions on the GoC websites regarding health risks of wireless technology (such as cell phones, baby monitors and other wireless RF emitting devices) and to halt wireless 5G rollout (focusing on fibre to the premises, FTTP) until public health safety can be assured.


Website says

#13. There are thousands of studies on the health effects of RF radiation. You can access many of them through the following links:

  • International Commission on Non-Ionizing Radiation Protection - publications
  • EMF Portal
  • Electromagnetic field literature search engine

Truth is

Two of the website links provided at the GoC websites are to organizations that adhere to the 1920s paradigm67 upon which the first 1979 Safety Code 6 was based, namely that RF radiation must heat to cause harm. Section 4 (below) discusses industry’s influence on the International Commission on Non-Ionizing Radiation Protection (ICNIRP).

The third link, EMF Portal (University of Aachen, Germany), can be very useful for finding RF radiation publications.

Two omissions from the GoC websites are the Australian based ORSAA database68 (a non-governmental scientific team) and Electromagnetic Radiation Safety69 (hosted by Dr. Joel Moskowitz, School of Public Health, University of California, Berkeley). Those are excellent resources to identify studies relevant to wireless radiation and health and the environment. C4ST has provided an overview summary of key peer-reviewed, published papers on our “Suspend 5G Canada Appeal” webpage.70


Website says

#14. The limits in Safety Code 6 are science-based exposure limits that are consistent with the science-based standards used in other parts of the world, including the United States, the European Union, Japan, Australia and New Zealand.

Truth is

The science-based exposure limits referred to are based on temperature only. China, Russia, Italy and Switzerland have safety standards 50 times safer than Canada’s for RF radiation exposures from equipment such as cell tower antennas.71


Website says

#15. The International Commission on Non-Ionizing Radiation Protection is referenced as an authority.

Truth is

Some of the biases and conflicts of interest in agencies that are involved in making recommendations for safe levels of RF radiation are discussed in the peer-reviewed paper by Frank Clegg et al. (2020).72

The “capture” of the US Federal Communications Commission (FCC) has been well documented.73

The International Commission on Non-Ionizing Radiation Protection (ICNIRP) is a private non-governmental organization based in Germany. New expert members can only be elected by members of ICNIRP. Many ICNIRP members have ties to the industry that must adhere to ICNIRP guidelines. The guidelines are of huge economic and strategic importance to the military, telecommunications/Information Technology (IT) and power industries.74

The published paper 75 outlines many reasons why governments should view critically any recommendations made by private organizations such as ICNIRP. More recently, a report was released by two members of the European Parliament about the conflicts of interests within ICNIRP.76


Website says

#16. To protect your health and safety, Health Canada scientists:
• Contribute to international efforts such as the World Health Organization EMF Project to assess potential health risks from radiofrequency EMF

Truth is

ICNIRP has a substantial influence on the World Health Organization’s International EMF Project as many of the key members are in both bodies.77


Website says

#17. Exposure to RF energy below the Canadian limits is safe. The limits are set far below the threshold (at least 50-fold safety margin) for all known established adverse health effects. Health Canada has incorporated several tiers of precaution into the limits to ensure safety, including a conservative threshold for the occurrence of adverse health effects, the use of worst-case exposure scenarios and an additional safety margin beyond the threshold.

Even a small child, following continuous exposure from multiple sources of RF energy, would not experience adverse health effects provided that the exposure limits set in Safety Code 6 are respected.

Truth is

This statement is inaccurate. There is ample science to demonstrate that RF energy (=radiation) is not safe below maximum exposure limits in Safety Code 6.

For clarity, terms will be discussed in the order they appeared in the above statements.

RF energy
This term can be used interchangeably with RF radiation for cell phone, cell antenna and 5G frequencies and health discussed in this document. It took decades for health authorities to act on the science that ionizing radiation (energy), e.g., X-rays, can cause cancer. Science is also telling us that non-ionizing radiation (energy), such as RF radiation from cell phones, can cause a wide range of health effects, including cancer. See Section 1.0. HEALTH RISKS.

Tiers of precaution
At first, this sounds highly precautionary, until the reader realizes that all of it is only based on temperature. In “tiers,” the only biological effect incorporated is heating of tissue that can be dissipated within 6 minutes. As a result, there is inadequate protection for Canadians.

Safe
There are two concerns regarding Health Canada's use of the word “safe.” First, this use of “safe” is not consistent with terms used in the regulation of other potential toxicants. Health Canada's claim that a regulated exposure (in this case, to RF radiation) is “safe” is (unacceptably) different from the norm, which should be stated as “poses acceptable risks when used according to the directions.” Second, the incorrect use of the word “safe” leads to over-assurance that engenders complacency, diminishes the perceived importance of hazards, and fosters unsafe behaviours.

Established adverse health effects
Health Canada references known, established, adverse effects, with reference only to consequences of over-heating of tissues. “Established” thus presents a logical fallacy. The much lower RF radiation exposure thresholds for effects observed by RF radiation researchers challenge, on solid scientific grounds, the stronger exposures permitted by Health Canada. Intermittent harms and incapacitation must be avoided. Temporary effects during activities such as driving a car, or climbing stairs or a ladder, pose risks to individuals as well as others. Other agents such as drugs are not regulated to avoid only the most serious, irreversible and readily observable acute effects. Health Canada’s process also disregards critical, subtle, long-term toxicities, as well as established synergisms with other toxicants.

For example, experiments may demonstrate an acute effect in particular individuals, at which point the argument is whether the established effect is adverse. Health Canada has taken the unrealistic stance that a reversible effect is generally not adverse because it is not permanent. As a result, individuals who experience non-permanent debilitating symptoms are left unprotected by Safety Code 6.

As ambient and unavoidable levels of RF radiation are increasing, and are projected to increase substantially with 5G, the portion of the population that is suffering daily is increasing. Effects that are initially reversible may become permanent in the long run, due to the cumulative effects of exposure, meeting Health Canada's definition of an adverse effect. Health Canada must re-assess its operational use of the word “adverse.”

Safety margins
There are two major concerns with the 50-fold safety margin under Safety Code 6. The baseline is not sound; and furthermore, a 50-fold is not a large margin of extrapolation (“safety factor”). Health Canada regulates other toxicants, such as pesticides, using extrapolation factors much greater than 50-fold; typically, many hundreds-fold. In addition, the investigation for the CBC Marketplace episode “The Secret Inside Your Cellphone” found that for cell phones held against the body, exposure levels are 3- to 4-fold above maximum exposure limits in Safety Code 6.

In France, measurements of radiation from cell phones demonstrated over 90% of the phones tested exceeded the safety standards.79

Effect on children
The assurances of no adverse health effects on children are based on temperature estimations. Health Canada has conducted no safety testing on children (Appendix C). See Section 2.3 for more on health risks of RF radiation and children.


Website says

#18. To protect your health and safety, Health Canada scientists:
• Conduct research on the potential health effects of radiofrequency EMF (electromagnetic exposures).

Truth is

This statement is misleading, as the reader would assume that Health Canada has conducted original research on frequencies that are of high relevance to Canadians, namely present-day cell phone, wireless network antenna and Wi-Fi emissions, and future 5G.

Health Canada has not.

Among the RF radiation publications by Health Canada since 1983 (Appendix C), original research that examines the effects of non-thermal (non-heating) effects is sparse. Of the studies on biological effects, there are no original research studies on Wi-Fi (2.45 GHz) or on 5G millimetre frequencies. Both of these frequency types are of concern to Canadians.

Some of these concerns and unaddressed questions are outlined in the Auditor General Environmental Petitions.80

Health Canada did conduct studies on one frequency, 1.9 GHz, that is relevant to cell phone and some other wireless device exposures, but it must be remembered that RF radiation exposures from wireless devices are complex and studying one frequency is not adequate to determine “safety” of complex technologies using pulsed signals of multiple frequencies.

Also of concern, there are no Canadian studies on possible adverse effects of living near cell towers even though numerous studies from elsewhere demonstrate adverse effects. 81, 82, 83


Website says

#19. A recent addition to the Government of Canada websites states: Misinformation and opinions on the health risks from exposure to radiofrequency EMF are increasing on social media and on the internet. Most recently, there have been claims linking the deployment of 5G networks to the novel coronavirus (COVID-19). There is no scientific basis for these claims. The World Health Organization (WHO) and the International Commission on Non-Ionizing Radiation Protection have also communicated this message.

Truth is

C4ST agrees that there is no scientific cause and effect linking deployment of 5G and the development or spread of the coronavirus.

Given the “misinformation,” i.e., misleading and inaccurate statements on the Health Canada and Innovation, Science and Economic Development (ISED) webpages, the Government of Canada should define what process is in place to assure the accuracy of information posted on its websites, and require the appropriate Ministers to undertake the necessary corrections, as misinformation harms public health.


STATEMENTS ARE FROM THE FOLLOWING GOVERNMENT OF CANADA (GoC) WEBSITES:

1. HEALTH CANADA
  1. Cell phones, cell phone towers and other antenna installations
    https://www.canada.ca/en/health-canada/services/health-risks-safety/radiation/everyday-things-emit-radiation/cell-phones-towers.html
  2. Fact Sheet – What is Safety Code 6?
    https://www.canada.ca/en/health-canada/services/environmental-workplace-health/reports-publications/radiation/fact-sheet-what-safety-code-6.html
2. INNOVATION, SCIENCE AND ECONOMIC DEVELOPMENT (ISED) – previously INDUSTRY CANADA (IC)
  1. Radiofrequency Energy and Safety
    https://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf11467.html

References and End Notes

[1] Health Canada. (2015). Limits of human exposure to radiofrequency electromagnetic energy in the frequency range from 3 KHz to 300 GHz. Safety Code 6 (2015), 24. Retrieved from http://www.hc-sc.gc.ca/ewh-semt/alt_formats/pdf/consult/_2014/safety_code_6-code_securite_6/final-finale-eng.pdf

[2] Health Canada’s Safety Code 6 (2015) recognizes only two “established, adverse” health effects from exposure to RF radiation: tissue heating with exposure to radiofrequencies in the higher range; and nerve stimulation at the lowest radiofrequencies. These lower frequencies are not presently in widespread use for wireless communications. C4ST’s comments refer to the higher frequencies where tissue heating is the only recognized adverse effect.

[3] Previously called Industry Canada.

[4] Canadians for Safe Technology (2020). Engaging Your Member of Parliament (MP) about 5G. C4ST’s Suggestions & Facts You Can Use to Reply to Your MP Regarding the Suspend 5G Canada Appeal.  http://docs.c4st.org/PubEngage/Take-Action-Tools/Engaging-MPs-about-5G.pdf

[5] Health Canada’s Safety Code 6 (2015) defines electromagnetic radiation as “A form of energy emitted by accelerating electric charges, that exhibits wave-like behaviour as it travels thorugh space.”

A Government of Canada webpage says, “Radiofrequency electromagnetic fields (EMF) are a type of non-ionizing electromagnetic radiation found on the electromagnetic spectrum covering the range of frequencies below 300 GHz. Radiofrequency EMF are invisible waves that travel through space and exert force on charged particles. These waves have been used for many years to transmit information between an antenna and a device without the use of wires.” [https://www.canada.ca/en/health-canada/services/health-risks-safety/radiation/types-sources/radiofrequency-fields.html [Accessed 12 Dec 2020] Note: the frequency range covered by Safety Code 6 is 3 kHz to 300 GHz.

[6] 5G Appeal of International Scientists.(2017, September). http://www.5gappeal.eu/

[7] Physicians’ Health Initiative for Radiation and Environment and British Society for Ecological Medicine. (2020, October 11). Press Release. 2020 Consensus Statement of UK and International Medical and Scientific Experts and Practitioners on Health Effects of Non-Ionising Radiation (NIR). Retrieved November 12, 2020, from https://phiremedical.org/wp-content/uploads/2020/11/Press-Release-2020-Non-Ionising-Radiation-Consensus-Statement-1.pdf

[8] Eight Canadian Non-Government Organizations. (2020). Urgent Appeal to the Government of Canada to Suspend the 5G Rollout. http://c4st.org/5Gappeal/

[9] Hardell, L., & Carlberg, M. (2020). Health risks from radiofrequency radiation, including 5G, should be assessed by experts with no conflicts of interest. Oncology Letters, 20(4). https://doi.org/10.3892/ol.2020.11876

[10] Simkó, M., & Mattsson, M.-O. (2019). 5G Wireless Communication and Health Effects—A Pragmatic Review Based on Available Studies Regarding 6 to 100 GHz. International Journal of Environmental Research and Public Health, 16(18), 3406. https://doi.org/10.3390/ijerph16183406

[11] Leszczynski, D. (2020). Physiological effects of millimeter-waves on skin and skin cells: An overview of the to-date published studies. Reviews on Environmental Health, 35(4). Epub ahead of print. https://doi.org/10.1515/reveh-2020-0056.

[12] Miller, A. B., Morgan, L. L., Udasin, I., & Davis, D. L. (2018). Cancer epidemiology update, following the 2011 IARC evaluation of radiofrequency electromagnetic fields (Monograph 102). Environmental Research, 167, 673–683. https://doi.org/10.1016/j.envres.2018.06.043

[13] Hardell, L., & Carlberg, M. (2018). Comments on the US National Toxicology Program technical reports on toxicology and carcinogenesis study in rats exposed to whole-body radiofrequency radiation at 900 MHz and in mice exposed to whole-body radiofrequency radiation at 1,900 MHz. International Journal of Oncology. https://doi.org/10.3892/ijo.2018.4606

[14] International Agency for Research on Cancer (IARC) Working Group on the Evaluation of Carcinogenic Risks to Humans. (2013). Non-ionizing Radiation, Part 2: Radiofrequency Electromagnetic Fields. IARC Monographs on the Evaluation of Carcinogenic Risks to Humans / World Health Organization, International Agency for Research on Cancer. https://Publications.Iarc.Fr/126, 102(Pt 2), 1–460.

[15] International Agency for Research on Cancer. (2019). Report of the Advisory Group to Recommend Priorities for the IARC Monographs during 2020–2024. Pages 148-149. https://monographs.iarc.fr/wp-content/uploads/2019/10/IARCMonographs-AGReport-Priorities_2020-2024.pdf

[16] Gittleman, H. R., Ostrom, Q. T., Rouse, C. D., Dowling, J. A., de Blank, P. M., Kruchko, C. A., … Barnholtz-Sloan, J. S. (2015). Trends in central nervous system tumor incidence relative to other common cancers in adults, adolescents, and children in the United States, 2000 to 2010. Cancer, 121(1), 102–112. https://doi.org/10.1002/cncr.29015

[17] Ostrom, Q. T., Gittleman, H., de Blank, P. M., Finlay, J. L., Gurney, J. G., McKean-Cowdin, R., … Barnholtz-Sloan, J. S. (2016). American Brain Tumor Association Adolescent and Young Adult Primary Brain and Central Nervous System Tumors Diagnosed in the United States in 2008-2012. Neuro-Oncology, 18(suppl 1), i1–i50. https://doi.org/10.1093/neuonc/nov297

[18] Philips, Alisdair, Henshaw, Denis L., Lamburn, Graham, & O’Carroll, Michael. (2018). Brain tumours: rise in Glioblastoma Muliforme incidence in England 1995-2015 suggests an adverse environmental or lifestyle factor. Journal of Environmental and Public Health, 20. Retrieved from https://www.hindawi.com/journals/jeph/aip/7910754/

[19] Ostrom, Q. T., Gittleman, H., Fulop, J., Liu, M., Blanda, R., Kromer, C., … Barnholtz-Sloan, J. S. (2015). CBTRUS Statistical Report: Primary Brain and Central Nervous System Tumors Diagnosed in the United States in 2008-2012. Neuro-Oncology, 17(suppl 4), iv1–iv62. https://doi.org/10.1093/neuonc/nov189

[20] Ostrom, Q. T., Cioffi, G., Gittleman, H., Patil, N., Waite, K., Kruchko, C., & Barnholtz-Sloan, J. S. (2019). CBTRUS Statistical Report: Primary Brain and Other Central Nervous System Tumors Diagnosed in the United States in 2012-2016. Neuro-Oncology, 21(Suppl 5), v1–v100. https://doi.org/10.1093/neuonc/noz150

[21] Momoli, F., Siemiatycki, J., McBride, M. L., Parent, M.-É., Richardson, L., Bedard, D., … Krewski, D. (2017). Probabilistic Multiple-Bias Modeling Applied to the Canadian Data From the Interphone Study of Mobile Phone Use and Risk of Glioma, Meningioma, Acoustic Neuroma, and Parotid Gland Tumors. American Journal of Epidemiology, 186(7), 885–893. https://doi.org/10.1093/aje/kwx157

[22] Coureau, Gaëlle, Ghislaine Bouvier, Pierre Lebailly, Pascale Fabbro-Peray, Anne Gruber, Karen Leffondre, Jean-Sebastien Guillamo, et al. (2014). Mobile Phone Use and Brain Tumours in the CERENAT Case-Control Study. Occupational and Environmental Medicine 71, no. 7: 514–22. https://doi.org/10.1136/oemed-2013-101754.

[23] Choi, Y.-J., Moskowitz, J. M., Myung, S.-K., Lee, Y.-R., & Hong, Y.-C. (2020). Cellular Phone Use and Risk of Tumors: Systematic Review and Meta-Analysis. International Journal of Environmental Research and Public Health, 17(21), 8079. https://doi.org/10.3390/ijerph17218079

[24] Carlberg, Michael, Tarmo Koppel, Lena K. Hedendahl, and Lennart Hardell. (2020). Is the Increasing Incidence of Thyroid Cancer in the Nordic Countries Caused by Use of Mobile Phones? International Journal of Environmental Research and Public Health 17, no. 23: 9129. https://doi.org/10.3390/ijerph17239129.

[25] Shih, Y.-W., O’Brien, A. Paul, Hung, C.-S., Chen, K.-H., Hou, W.-H., & Tsai, H.-T. (2021). Exposure to radiofrequency radiation increases the risk of breast cancer: A systematic review and meta-analysis. Experimental and Therapeutic Medicine, 21(1). https://doi.org/10.3892/etm.2020.9455

[26] Houston, B. J., Nixon, B., King, B. V., De Iuliis, G. N., & Aitken, R. J. (2016). The effects of radiofrequency electromagnetic radiation on sperm function. Reproduction (Cambridge, England), 152(6), R263–R276. https://doi.org/10.1530/REP-16-0126

[27] Panagopoulos, D. J. (2019). Comparing DNA damage induced by mobile telephony and other types of man-made electromagnetic fields. Mutation Research/Reviews in Mutation Research, 781, 53–62. https://doi.org/10.1016/j.mrrev.2019.03.003

[28] Levitt, B. B., & Lai, H. (2010). Biological effects from exposure to electromagnetic radiation emitted by cell tower base stations and other antenna arrays. Environmental Reviews, 18, 369–395. https://doi.org/DOI: 10.1139/a10-903

[29] Zothansiama, -, Zosangzuali, M., Lalramdinpuii, M., & Jagetia, G. C. (2017). Impact of radiofrequency radiation on DNA damage and antioxidants in peripheral blood lymphocytes of humans residing in the vicinity of mobile phone base stations. Electromagnetic Biology and Medicine, 36:3, 295-305. https://doi.org/10.1080/15368378.2017.1350584

[30] CBC Marketplace. (2017). The Secret Inside Your Cellphone. https://www.cbc.ca/player/play/910329411834.

[31] Fernández, C., de Salles, A. A., Sears, M. E., Morris, R. D., & Davis, D. L. (2018). Absorption of wireless radiation in the child versus adult brain and eye from cell phone conversation or virtual reality. Environmental Research, 167, 694–699. https://doi.org/10.1016/j.envres.2018.05.013

[32] Butler, T. (2020, May 18). Evidence of the Risks to Children from Smartphone and WiFi Radio Frequency Radiation. https://ehtrust.org/evidence-of-the-risks-to-children-from-smartphone-and-wifi-radio-frequency-radiation-by-professor-tom-butler-univers/

[33] Health Canada. (2015). Limits of human exposure to radiofrequency electromagnetic energy in the frequency range from 3 KHz to 300 GHz. Safety Code 6 (2015), Section 2.1.2.  http://www.hc-sc.gc.ca/ewh-semt/alt_formats/pdf/consult/_2014/safety_code_6-code_securite_6/final-finale-eng.pdf

[34] CBC Marketplace. (2017). The Secret Inside Your Cellphone. https://www.cbc.ca/player/play/910329411834.

[36] Miller, A. B., Morgan, L. L., Udasin, I., & Davis, D. L. (2018). Cancer epidemiology update, following the 2011 IARC evaluation of radiofrequency electromagnetic fields (Monograph 102). Environmental Research, 167, 673–683. https://doi.org/10.1016/j.envres.2018.06.043

[37] Hardell, L., & Carlberg, M. (2018). Comments on the US National Toxicology Program technical reports on toxicology and carcinogenesis study in rats exposed to whole-body radiofrequency radiation at 900 MHz and in mice exposed to whole-body radiofrequency radiation at 1,900 MHz. International Journal of Oncology. https://doi.org/10.3892/ijo.2018.4606

[38] National Toxicology Program, National Institute of Environmental Health Sciences. (2020). Cell Phone Radio Frequency Radiation. https://ntp.niehs.nih.gov/whatwestudy/topics/cellphones/index.html

[39] Falcioni, L., Bua, L., Tibaldi, E., Lauriola, M., De Angelis, L., Gnudi, F., … Belpoggi, F. (2018). Report of final results regarding brain and heart tumors in Sprague-Dawley rats exposed from prenatal life until natural death to mobile phone radiofrequency field representative of a 1.8 GHz GSM base station environmental emission. Environmental Research. https://doi.org/10.1016/j.envres.2018.01.037

[40] Houston, B. J., Nixon, B., King, B. V., De Iuliis, G. N., & Aitken, R. J. (2016). The effects of radiofrequency electromagnetic radiation on sperm function. Reproduction (Cambridge, England), 152(6), R263–R276. https://doi.org/10.1530/REP-16-0126

[41] Magras, I. N., & Xenos, T. D. (1997). RF radiation-induced changes in the prenatal development of mice. Bioelectromagnetics, 18(6), 455–461. https://pubmed.ncbi.nlm.nih.gov/9261543/

[42] Aldad, T. S., Gan, G., Gao, X.-B., & Taylor, H. S. (2012). Fetal radiofrequency radiation exposure from 800-1900 mhz-rated cellular telephones affects neurodevelopment and behavior in mice. Scientific Reports, 2, 312. https://doi.org/10.1038/srep00312

[43] Panagopoulos, D. J. (2019). Comparing DNA damage induced by mobile telephony and other types of man-made electromagnetic fields. Mutation Research/Reviews in Mutation Research, 781, 53–62. https://doi.org/10.1016/j.mrrev.2019.03.003

[44] National Toxicology Program, National Institute of Environmental Health Sciences. (2020). Cell Phone Radio Frequency Radiation. https://ntp.niehs.nih.gov/whatwestudy/topics/cellphones/index.html

[45]  National Toxicology Program, National Institute of Environmental Health Sciences. (2018). Toxicology and carcinogenesis studies in Hsd: Sprague Dawley SD rats exposed to whole-body radio frequency radiation at a frequency (900 MHz) and modulations (GSM and CDMA) used by cell phones. NTP Technical Report 595, 384. https://ntp.niehs.nih.gov/ntp/htdocs/lt_rpts/tr595_508.pdf?utm_source=direct&utm_medium=prod&utm_campaign=ntpgolinks&utm_term=tr595

[46] National Toxicology Program, National Institute of Environmental Health Sciences. (2018). Toxicology and carcinogenesis studies in B6C3F1/n mice exposed to whole-body radio frequency radiation at a frequency (1,900 mHz) and modulations (GSM and CDMA) used by cell phones. NTP Technical Report 596, 260. https://ntp.niehs.nih.gov/ntp/htdocs/lt_rpts/tr596_508.pdf?utm_source=direct&utm_medium=prod&utm_campaign=ntpgolinks&utm_term=tr596

[47] Smith-Roe, S. L., Wyde, M. E., Stout, M. D., Winters, J. W., Hobbs, C. A., Shepard, K. G., … Witt, K. L. (2020). Evaluation of the genotoxicity of cell phone radiofrequency radiation in male and female rats and mice following subchronic exposure. Environmental and Molecular Mutagenesis, 61(2), 276-290 https://doi.org/10.1002/em.22343

[48] Pall, M. L. (2015). Scientific evidence contradicts findings and assumptions of Canadian Safety Panel 6: microwaves act through voltage-gated calcium channel activation to induce biological impacts at non-thermal levels, supporting a paradigm shift for microwave/lower frequency electromagnetic field action. Reviews on Environmental Health, 30(2), 99–116. https://doi.org/10.1515/reveh-2015-0001

[49] Cook, Harold J., Steneck, N. H., Vander, A. J., & Kane, G. L. (1980). Early research on the biological effects of microwave radiation: 1940-1960. Annals of Science, 37(3), 323–351. Page 326. https://doi.org/10.1080/00033798000200271 Retrieved from https://www.magdahavas.com/wp-content/uploads/2011/02/Early_Research_on_the_Biological_Effects_of_Microwave_Radiation_1940-1960.pdf

[50] Clegg, F. M., Sears, M., Friesen, M., Scarato, T., Metzinger, R., Russell, C., … Miller, A. B. (2020). Building science and radiofrequency radiation: What makes smart and healthy buildings. Building and Environment, 176, 106324. https://doi.org/10.1016/j.buildenv.2019.106324

[51] Rooney, A. A., Boyles, A. L., Wolfe, M. S., Bucher, J. R., & Thayer, K. A. (2014). Systematic Review and Evidence Integration for Literature-Based Environmental Health Science Assessments. Environmental Health Perspectives, 122:711–718. https://doi.org/10.1289/ehp.1307972

[52] Cook, Harold J., Steneck, N. H., Vander, A. J., & Kane, G. L. (1980). Early research on the biological effects of microwave radiation: 1940-1960. Annals of Science, 37, 323–351. Page 326. https://doi.org/10.1080/00033798000200271  Retrieved from https://www.magdahavas.com/wp-content/uploads/2011/02/Early_Research_on_the_Biological_Effects_of_Microwave_Radiation_1940-1960.pdf

[53] Canadians for Safe Technology. (2017). References of over 200 scientific studies and six (6) reviews reporting potential harm at non-thermal (not heating) levels of radiofrequency/microwave radiation that are below Safety Code 6 (2015). http://docs.c4st.org/Studies/original-references_of_over_200_scientific_studies_showing_potential_harm_at_levels_below_safety_code_6.pdf

[54] CBC Marketplace. (2017). The Secret Inside Your Cellphone. https://www.cbc.ca/player/play/910329411834.

[55] Canadians for Safe Technology. (2016). Summary graph of 140 studies omitted during the last revision of Safety Code 6. See Figure 3 in: References of over 200 scientific studies and six (6) reviews reporting potential harm at non-thermal (not heating) levels of radiofrequency/microwave radiation that are below Safety Code 6 (2015). http://docs.c4st.org/Studies/original-references_of_over_200_scientific_studies_showing_potential_harm_at_levels_below_safety_code_6.pdf

[56] Health Canada. (2015). Safety Code 6 (2015) – Rationale. (Unpublished discussion paper), 62 pages. http://docs.c4st.org/GovRelations/Fed/Health-Canada/Health-Canada-Safety-Code-6-2015-Rationale_62-pages_Unpublished-discussion-paper.pdf

[57] Miller, A. B., Sears, M. E., Morgan, L. L., Davis, D. L., Hardell, L., Oremus, M., & Soskolne, C. L. (2019). Risks to Health and Well-Being From Radio-Frequency Radiation Emitted by Cell Phones and Other Wireless Devices. Frontiers in Public Health, 7. https://doi.org/10.3389/fpubh.2019.00223

[58] Choi, Y.-J., Moskowitz, J. M., Myung, S.-K., Lee, Y.-R., & Hong, Y.-C. (2020). Cellular Phone Use and Risk of Tumors: Systematic Review and Meta-Analysis. International Journal of Environmental Research and Public Health, 17(21), 8079. https://doi.org/10.3390/ijerph17218079

[59]Cook, Harold J., Steneck, N. H., Vander, A. J., & Kane, G. L. (1980). Early research on the biological effects of microwave radiation: 1940-1960. Annals of Science, 37(3), 323–351. Page 326. https://doi.org/10.1080/00033798000200271 Retrieved from https://www.magdahavas.com/wp-content/uploads/2011/02/Early_Research_on_the_Biological_Effects_of_Microwave_Radiation_1940-1960.pdf

[60] European Environment Agency (2013). Late Lessons from Early Warnings: Science, Precaution, Innovation. Volume II. European Environment Agency (EEA), Copenhagen, Denmark. Report No1/2013, https://www.eea.europa.eu/publications/late-lessons-2

[61] Eight Canadian Non-Government Organizations. (2020, May). Urgent Appeal to the Government of Canada to Suspend the 5G Rollout. http://c4st.org/5Gappeal/

[62] Rooney, A. A., Boyles, A. L., Wolfe, M. S., Bucher, J. R., & Thayer, K. A. (2014). Systematic Review and Evidence Integration for Literature-Based Environmental Health Science Assessments. Environmental Health Perspectives, 122:711–718. https://doi.org/10.1289/ehp.1307972

[63] Webster, P. C. (2014). Federal Wi-Fi safety report is deeply flawed, say experts. CMAJ: Canadian Medical Association Journal = Journal de l’Association Medicale Canadienne, 186(9), E300. https://doi.org/10.1503/cmaj.109-4785

[64] Huh, N. Y. (2014, April 15). Canadian scientists urge more research into safety of wireless technology, saying recent report downgrades cancer risk. National Post. Retrieved from https://nationalpost.com/health/canadian-scientists-urge-more-research-into-safety-of-wireless-technology-saying-recent-report-downgrades-cancer-risk

[65] Rooney, A. A., Boyles, A. L., Wolfe, M. S., Bucher, J. R., & Thayer, K. A. (2014). Systematic Review and Evidence Integration for Literature-Based Environmental Health Science Assessments. Environmental Health Perspectives, 122:711–718. https://doi.org/10.1289/ehp.1307972

[66] EMF Scientist. (2015). International Appeal: Scientists call for protection from non-ionizing electromagnetic field exposure. Eur. J. Oncol., 20(3/4), 180–182 https://mattioli1885journals.com/index.php/EJOEH/article/view/4971 and https://www.emfscientist.org/ [accessed 6 December 2020]

[67] Cook, Harold J., Steneck, N. H., Vander, A. J., & Kane, G. L. (1980). Early research on the biological effects of microwave radiation: 1940-1960. Annals of Science, 37(3), 323–351. Page 326. https://doi.org/10.1080/00033798000200271 Retrieved from https://www.magdahavas.com/wp-content/uploads/2011/02/Early_Research_on_the_Biological_Effects_of_Microwave_Radiation_1940-1960.pdf

[68] Oceania Radiofrequency Scientific Advisory Association. https://www.orsaa.org/

[69] Electromagnetic Radiation Safety website. https://www.saferemr.com

[70] Eight Canadian Non-Government Organizations. 2020. Supplemental Material: Suspend 5G Canada Appeal. http://docs.c4st.org/Studies/Supplemental-Material-for-Suspend-5G-Canada-Appeal_Key-Papers-in-Peer-reviewed-Journals.pdf

[71] Clegg, F. M., Sears, M., Friesen, M., Scarato, T., Metzinger, R., Russell, C., … Miller, A. B. (2020). Building science and radiofrequency radiation: What makes smart and healthy buildings. Building and Environment, 176, 106324. https://doi.org/10.1016/j.buildenv.2019.106324

See Figure 3: Data obtained from:

1) World Health Organization, Global Health Observatory. (2017). Exposure limits for radio-frequency fields (public) - data by country, http://apps.who.int/gho/data/node.main.EMFLIMITSPUBLICRADIOFREQUENCY?lang=en (2017) and
2) Mazar H. (2016). Human radio frequency exposure limits: an update of reference levels in Europe, USA, Canada, China, Japan and Korea. 2016 International Symposium on Electromagnetic Compatibility - EMC EUROPE, IEEE, Wroclaw, Poland (2016), pp. 467-473, 10.1109/EMCEurope.2016.7739164 https://www.researchgate.net/publication/303055416_Human_Radio_Frequency_Exposure_Limits_an_update_of_reference_levels_in_Europe_USA_Canada_China_Japan_and_Korea

[72] Clegg, F. M., Sears, M., Friesen, M., Scarato, T., Metzinger, R., Russell, C., … Miller, A. B. (2020). Building science and radiofrequency radiation: What makes smart and healthy buildings. Building and Environment, 176, 106324. https://doi.org/10.1016/j.buildenv.2019.106324

[73] Alster, Norm. (2017). Captured Agency: How the Federal Communications Commission is Dominated by the Industries it Presumably Regulates. https://ethics.harvard.edu/files/center-for-ethics/files/capturedagency_alster.pdf

[74] Hardell, L. (2017). World Health Organization, radiofrequency radiation and health - a hard nut to crack (Review). International Journal of Oncology, 51(2), 405–413. Retrieved from http://www.spandidos-publications.com/ijo/51/2/405/abstract

[75] Domenech-Pascual, G. (2013). Not Entirely Reliable: Private Scientific Organizations and Risk Regulation – The Case of Electromagnetic Fields.European Journal of Risk Regulation, 4(1), 29-42. Retrieved from Social Science Research Network https://papers.ssrn.com/abstract=2902287

[76] van Scharen, H., Buchner, K., & Rivasi, M. (2020). The International Commission on Non-Ionizing Radiation Protection: Conflicts of interest, corporate capture and the push for 5G. This report was commissioned, coordinated and published by two members of the European Parliament –Michèle Rivasi (Europe Écologie) and Klaus Buchner (Ökologisch-Demokratische Partei), and financed by the Greens/EfAgroup in the European Parliament. 98. Retrieved from https://klaus-buchner.eu/wp-content/uploads/2020/06/ICNIRP-report-FINAL-19-JUNE-2020.pdf

[77] Hardell, L., & Carlberg, M. (2020). Health risks from radiofrequency radiation, including 5G, should be assessed by experts with no conflicts of interest. Oncology Letters, 20(4). https://doi.org/10.3892/ol.2020.11876

[78] CBC Marketplace. (2017). The Secret Inside Your Cellphone. https://www.cbc.ca/player/play/910329411834.

[80] Canadians for Safe Technology. (2020). Compendium of Auditor General Environmental Petitions (22) and Government of Canada Replies Regarding Radiofrequency/microwave Radiation Related to Health Canada’s Safety Code 6. Submitted 2007 to 2017, inclusive. Office of the Auditor General of Canada. Petitions Catalogue. 651 pages. http://docs.c4st.org/GovRelations/Fed/Auditor-General/Compendium_Environmental-Petitions-Submitted-to-AG-and-Govt-of-Canada-Replies_Dec-23-2020.pdf

[81] Levitt, B. B., & Lai, H. (2010). Biological effects from exposure to electromagnetic radiation emitted by cell tower base stations and other antenna arrays. Environmental Reviews, 18, 369–395. https://doi.org/DOI: 10.1139/a10-903

[82] Gómez-Perretta, C., Navarro, E. A., Segura, J., & Portolés, M. (2013). Subjective symptoms related to GSM radiation from mobile phone base stations: a cross-sectional study. BMJ Open, 3(12), e003836. https://doi.org/10.1136/bmjopen-2013-003836

[83] Zothansiama, -, Zosangzuali, M., Lalramdinpuii, M., & Jagetia, G. C. (2017). Impact of radiofrequency radiation on DNA damage and antioxidants in peripheral blood lymphocytes of humans residing in the vicinity of mobile phone base stations. Electromagnetic Biology and Medicine, 36:3, 295-305. https://doi.org/10.1080/15368378.2017.1350584

[84] Government of Canada, (2019, June 7). Decision on Releasing Millimetre Wave Spectrum to Support 5G [Consultation Reports]. http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf11510.html

[85] Government of Canada. (2018, July 9). Comments received on Gazette Notice SLBP-005-18 [Navigation Pages]. http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf11421.html