by John W. Gofman, 10/2/98 October 2, 1998John W. Gofman, M.D., Ph.D.
Dr. Christopher Portier and Dr. Mary S. Wolfe
San Francisco, CA
EMF-RAPID Program/LCBRA
NIEHS, NIH
PO Box 12233, MD EC-16
Research Triangle Park NC 27709Dear Drs. Portier and Wolfe:
I have received the full 500-page "Working Group Report" on identifying (not quantifying) potential health hazards from exposure to power-line frequency EMFs (NIH Pub. 98-3981). You invite comments, especially about the group's vote (by 19 out of 30 members) to classify ELF EMFs as "possibly carcinogenic to humans" (p.396), according to IARC criteria.
Like some members of your Working Group (p.8), I have no direct expertise in ELF EMF epidemiology or ELF EMF interaction with human tissue. But I have about 55 years of experience in research: First as a nuclear chemist on the A-bomb project 1940-43, then in the laboratory work which opened the world of diverse lipoproteins, simultaneously in epidemiology as we did the first case-control studies and the first prospective studies which showed elevated rates of heart attacks in persons with elevated levels of serum lipoproteins of various classes (Gofman 1996-a), thereafter in the laboratory doing xray spectroscopy on trace minerals in the blood, followed by laboratory work on the association between chromosomal aberrations and cancer, the xray induction of genomic instability, and the epidemiology of low-dose ionizing radiation and cancer. My CV is attached. Recently, I served on one of the NIH "Working Groups" (part of the National Action Plan on Breast Cancer). My comments follow:
1. On the basis of existing evidence, it seems very reasonable to classify ELF EMFs as "possibly carcinogenic to humans."
2. Even if the vote had gone the other way, it is imperative that research be intensified on this aspect of EMFs. Why?
Due to the repeated finding of suggestive evidence of carcinogenicity. The absence of conclusive epidemiologic data provides no assurance that adverse effects are negligibly small. Atherogenic lipoproteins were killing people long before adverse effects were provably connected with such entities (whose spectrum was not even known until the 1949-1953 period). The repeated failures, before 1950, to obtain epidemiologically conclusive evidence of the connection was largely due to measurement of the wrong entities (Gofman 1950, pp.6-7). Today, almost no one denies that atherogenic lipoproteins play a huge role in causing both Coronary Heart Disease and its acute fatal events --- although the mechanisms are still under intense research. It is clear from your report that a similar pitfall may be present in your field (no pun intended): Measurement of the wrong properties (p.9, pp.382-384, for example).
There are additional ways in which epidemiology can fail to demonstrate real and non-negligible cancer effects. Suppose in some of your key studies, there happened to be an unmatched or even an inverse relationship between exposure-level to ELF EMFs and exposure-level to some other carcinogen (medical xrays, for example, especially in your adult studies)? This is not a far-fetched possibility, since (a) so few studies even try to match dose-groups for medical xray exposure, and (b) it is virtually impossible to quantify with any reliability people's accumulated dose from a lifetime of medical xrays.
A premature decision by NIEHS and Congress to relegate ELF EMF research to low priority could turn out to be tragic.
3. In view of the coming intensification of worldwide exposure to microwaves from telecommunications, that aspect of EMF research urgently needs intensification too. If it turns out that microwaves do cause adverse health effects, the sooner we know it, the sooner the engineers might find ways to drive the communications revolution (for which I am an enthusiast) with less exposure. It would be a serious mistake to assume that progress and caution are necessarily mutually exclusive. For example, the xray dose from mammography was reduced more than 10-fold while improving the quality of the diagnostic information (Gofman 1996-b, Chap.28). The incentive began with one man (John C. Bailar III, M.D., Ph.D., now at the Univ. of Chicago), who objected to the cancer-consequences of mass screening at the planned dose-level. Even with high-dose therapeutic xrays (which can have some nasty side-effects in addition to second cancers), radiation specialists are succeeding in appreciably reducing the amount of tissue irradiated, with no loss of benefit --- with only an increased benefit.
4. In the absence of conclusive evidence about adverse health effects from EMFs, there is a troubling ethical issue which NIEHS and Congress should not overlook. People are getting exposed without their consent to an agent of unknown toxicity. The fact, that this is true also for most chemical pollutants, does not make it morally defensible. The doctrine, that there is a right to expose people unless they (or their government) can prove harm, amounts to enrolling the population in a giant biological experiment without consent. And after harm is established, the cost-benefit doctrine of pollution takes over, and this doctrine still assumes a polluter's right to expose people without their consent, as long as the majority of 535 members of Congress decree that the economic benefit to society (and possibly to certain Congressmen and polluters) is "worth it."
5. In view of the enormous economic pressure not to find conclusive evidence of adverse health effects from EMFs, I think your report is remarkably informative. I am particularly impressed by the open acknowledgment that interactions between ELF EMFs and cells should not be regarded as implausible (pp.382-384). Some analysts have used the mass media to ridicule the idea.
6. Also, I am impressed by the fact that the Working Group meeting was open to the public (p.8). And by the policy of including Minority Reports (which was not the policy of the Working Group in which I participated).
7. However, I am troubled by the fact that the Working Group must have had no control over the press release which accompanied its report, for the press mis-characterized it as finding a negligible hazard --- whereas the report does not attempt to evaluate the magnitude at all. It seems to me that every Working Group has a nearly sacred right to characterize its own report. This key aspect of the members' public service must not be denied to them.
8. I am extremely troubled by the revelation (p.7) that your five-year effort was "jointly funded by Federal and matching private funds." I do not see in the report any disclosure of the total budget, the share funded by private interests, and the identity of the private funders. Did I miss it? This seems like a terrible omission, in view of the potential conflicts of interest in EMF research (I refer to huge industries with perceived "need" to deny any adverse health effects).
9. Indeed, because of the potential conflict of interest in such research, I urge NIEHS to adopt a policy --- starting with a website addendum to this report --- of requiring every member of a Working Group, Task Force, Advisory Panel, etc. to disclose the source and amount of his/her past and current funding, and if at a university, any benefactors of his or her department. If judges, non-profit board members, lawyers, security analysts, and many other high-status professionals routinely disclose their sources of funding --- without claiming that such disclosure impugns their integrity --- then scientists deserve no exemption. As you know, journals routinely ask for such disclosure from scientists. But I find no clue about past and current funding of the various experts named on pages 1-4. Nor do I find any discussion of the "interests" of those who picked the 30 Working Group members, and the criteria for selecting Dr. X instead of Dr. Y for a slot.
10. It is self-evident that scientific truth can never be established by vote --- and certainly not by only 30 participants, no matter how objective and brilliant. (Indeed, sometimes even a genuine consensus of nearly everyone in a field has been wrong). Therefore, the selection of your 30 members was key. Another sample of experts might have had quite a different vote. In the field of ionizing radiation, some expert committees are about as predictable as the tobacco institute. Dissenters from "sponsor-friendly" views are not selected for membership.
11. Membership is not the only issue. The literature which any panel studies may itself be biased by biased sources of funding. As an Associate Director at the Livermore Lab in the A.E.C. days (1963-1969), and later, I became aware of how --- through denial of research funds --- a dominant research-sponsor with a point of view can arrange an artificial sponsor-friendly consensus in the universities and literature.
12. It seems to me that if the public, Congress, and the Administration really want to protect humanity from the possibly deadly effects of biased biomedical research with respect to pollutants, they should set aside 10% of the research budget on any pollutant for use by scientists whose assignment would be to uncover and publicize its potential worst-case aspects. Their job would be to guarantee that society learned about the "downside" potential and to guarantee that the polluters would have to face those issues in the open. In the absence of systematic funding for "adversary science," the odds heavily favor the outcome described in Pt.11.
13. I note that you (p.7) say that your 5-year effort was "designed to improve our understanding of the potential adverse health effects of exposure to extremely low frequency (ELF) EMF." That sounds like what I have described in Pt. 12. Is it?
14. In closing, I wish to say that your report is very well organized, and that I appreciate all of its user-friendly aspects --- the list of abbreviations, the glossary, the format of the reference list. I hope that no one takes any personal offense from my raising the issue of conflict of interest. I regard it as a generic problem with respect to most pollutants, because there are large economic and therefore political interests at work. I hope that you will consider my Points 8 through 13 in that spirit.
References cited:
John W. Gofman, M.D., Ph.D.
Professor Emeritus of Molecular and Cell Biology
University of California at Berkeley.
Attached: CV and Gofman 1996-a.
- Gofman 1950 (John W.) + Frank Lindgren + Harold Elliott + 4
- more colleagues, "The Role of Lipids and Lipoproteins in Atherosclerosis," Science 111, No.2877: 166-171 + 186.
- Gofman 1996-a (John W.), "Atherosclerotic Heart Disease and
- Cancer: Looking for the `Smoking Guns'," Milestones in Biological Research Series, FASEB Journal 10: 661-663.
- Gofman 1996-b (John W.), Preventing Breast Cancer: The Story
- Of A Major, Proven, Preventable Cause Of This Disease, Second Edition. (CNR Books, San Francisco.)