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JOE Igbokwe’s article published in ThisDay newspaper of 13 August, 2006 titled “Five years of GSM in Nigeria” at page 19 was interesting albeit provocative. It was interesting to the extent that it acknowledges the contributions of GSM to the increase in GDP witnessed in Nigeria since the liberalization of telecommunications. Joe Igbokwe stated that “GSM moved the speed of business transactions to an unprecedented level. It also took pressure off our roads. Time and energy have been saved. We have also recorded tremendous growth in the provision of infrastructure. As a matter of fact, GSM brought revolution in the way we do things in Nigeria.”
This unalloyed acknowledgment of the benefits of telephony to the economy, coming from an informed commentator of Igbokwe’s stature, gladdens the hearts of those of us actively involved in the process of bridging the digital divide between the haves and the have-nots through the provision of mobile communications services.
Igbokwe, however, raised some concerns about the effects of GSM operations on the environment. Apparently relying on a story published in The Guardian of Monday, May 9, 2006, and on a few letters received by the agency he heads, the Lagos State Infrastructure Management and Regulatory Agency (LASIMRA), posited that operators, through acts of omission or commission, have “compromised the very important issue of safety and standards….” If this were so, all stakeholders in the GSM revolution including, most importantly, the general public should be justifiably concerned. But it appears that Igbokwe’s conclusions are based on an obvious lack of information on the subject. Essentially, the questions are: Does Radio Frequency (RF) Emissions cause cancer (mobile phones communicate with base stations using RF energy); and, have operators (in this case, GSM operators) “compromised the very important issue of safety and standards?”
RF energy is a form of electromagnetic energy (EME). EME is found in various forms in the world we live in. It is produced in nature during thunder storms. The very magnetic pull of the earth that causes a compass to always point to the North is a form of EME. EME consists of electric and magnetic energy moving together (radiating) through space. Other forms of EME include gamma rays, x-rays and light. Incidentally, while one can arguably say that the most important use of the RF form of EME is in wireless communications, (this includes Radio, TV broadcasting and telephony) it is also used in microwave ovens, radar, industrial heaters and sealers, and medical treatments. While EME is used in different applications, it must be understood that the different modes of its use interact with biological materials in different ways. EME at particular frequencies can ionize biological materials. (Ionization refers to the process where electrons are stripped away from their normal locations in atoms and molecules. Examples of ionizing EME include x-rays and gamma rays which have very high frequencies). Mobile phones and their base stations operate at much lower frequencies and the energy is much too low to break chemical bonds. RF is thus referred to as non-ionizing radiation.
The fears exhibited by Igbokwe, with regards to the possible adverse effects of RF on humans, has been an issue over time. Environmentalists, including World Health Organisation (WHO) experts have long researched into the possibility that RF has harmful biological effects. Thousand’s of studies have been conducted, and are still being conducted on the issue. One fact has emerged from all this and that is that there is no scientific proof that RF is harmful. Naturally, this assertion will not be enough to assuage the fears of the general public.
Where scientific proof does not exist that a particular desirable invention has adverse effects, the Precautionary Principle is employed in determining the use of such an invention. For the avoidance of doubt, the Precautionary Principle is included in the 1992 Rio Declaration on Environment and Development and is invoked when: there is good reason to believe that harmful effects may occur to human, animal or plant health or to the environment, and the level of scientific uncertainty about the consequences or likelihood of the risk is such that the best available scientific advice cannot assess the risk with sufficient confidence to inform decision making. When the Precautionary principle is applied, international best practice dictates that an unbiased authority determines acceptable minimum standards which should guide the use of such an invention.
With respect to possible risks that might emanate from RF, the WHO collaborates with the International Commission on Non-Ionizing Radiation Protection (ICNIRP) to determine and set acceptable standards of safety. ICNIRP is a body of independent scientific experts consisting of a main Commission of 14 members, Four Scientific Standing Committees covering Epidemiology, Biology, Dosimetry and Optical Radiation and a number of consulting experts. This expertise is brought to bear on addressing the important issues of possible adverse effects of exposure to non-ionizing radiation on human health. Applying the Precautionary Principle is essentially a matter of making assumptions about consequences and likelihoods to establish credible scenarios, and then using standard procedures of risk assessment and management to inform decisions on how to address the possible hazard or threat.
While all scientific evidence points to the fact that RF emissions at particular frequencies have no identifiable adverse effects on biological tissue, the fears expressed by the general public and an application of the Precautionary Principle enjoined ICNIRP and other organizations to set standards that are well below levels at which any form of possible effect has been recorded. Normally the quantity used to measure how much RF energy is actually absorbed by the body is designated as Specific Absorption Rate (SAR).
The SAR is usually expressed in units of watts per kilogram (W/kg) or milliwatts per gram (mW/g) and ICNIRP has identified a whole-body SAR of 4 watts per kilogram (4W/kg) as a threshold level of exposure at which harmful biological effects may occur. To determine acceptable guidelines for the public, ICNIRP applied a 10-fold safety margin for occupational exposure guidelines and an additional 5-fold safety margin for exposure guidelines for the general public. Finally, following detailed engineering and physics studies to establish the relationship of power densities the standardization organizations set highly conservative public exposure guidelines that is only 2% of the level where potentially harmful biological effects have actually been demonstrated. ICNIRP set its public exposure standard at 0.40 mW/cm-sq at 800 MHz and 0.90 mW/cm-sq at 2000MHz. Interestingly, GSM base stations radiate at less than 0.0001 mW/cm-sq; this is less than 0.01% of ICNIRP public exposure guidelines.
In Nigeria, GSM companies adhere strictly to the guidelines set by ICNIRP. Before any body refers to the fabled ‘Nigerian factor’, it should be noted that the same equipment used in the most advanced countries of the world are used in Nigeria, and they are deployed by the same equipment vendors; Ericsson, Motorola, Siemens, Huawei, Nokia etc. who are all members of the Mobile Manufacturers Forum ((MMF)the interest group of all mobile equipment manufacturers) and GSM Association ((GSMA), the global trade association for mobile operators) These equipments are type approved by the NCC and accord with the best standards in the world; the industry associations, outside of legal requirements in the Nigerian Communications Act and the Digital Mobile Licenses (DML) granted the operators, through self regulatory initiatives, insist on it.
Previous studies and ongoing efforts have yet to show a causative link between base station RF emission and cancer as postulated by Igbokwe. In truth, if such exist, it will probably be more of an issue in the more developed economies where most antennae are deployed on rooftops of both private and commercial buildings. The Courts in England have given judicial endorsement to the standards set by ICNIRP. In the judgment of the Leeds Combined Court in Re: St. Margaret Hawes (No. 215 of 2002) and Holy Trinity Knaresborough (No.223 of 2002), where residents of a particular locality went to court to prevent the installation of antennae on the roofs of their local church, the relevant issue for determination was whether radio waves from a telecommunication mast (Base Station) situated as proposed may affect the health of humans living in the vicinity of the churches.
The Court noted in its judgment that the Petitioners’ expert witness affirmed that Vodafone operates within the ICNIRP guidelines and that the company’s base station emission levels are in practice “several hundreds, if not thousands, of times below that of the theoretical calculations”. Interestingly, the petitioners sought to stop the installation arguing that the perceived risk, even if not real or supported by scientific evidence, constituted sufficient grounds for the court to find in their favor. The court also rejected this argument, opining that perception cannot substitute for actual hazard.
In Nigeria, the Federal Ministry of Environment during the recent public hearing on Vmobile’s Environmental Impact Assessment (EIA) stated clearly that RF emissions do not have adverse effects on human health. Again, the NCC, through its highest official, the Executive Vice Chairman (EVC), has had cause to comment on the issue of RF emissions and its effect on human health. The EVC in the course of the last consumer parliament actually opined that he would not be so irresponsible as to risk the health of Nigerians, including his own offspring.
I believe that the forgoing has lain to rest Igbokwe’s contention that operators, through acts of omission or commission, have “compromised the very important issue of safety and standards….” In truth, safety and standards are scrupulously adhered to by GSM operators, and meticulously monitored by the NCC.
One may posit that Igbokwe’s position is based on paucity of the relevant information to reach a contrary conclusion. Other factors however suggest otherwise.
Increasingly, government agencies, at all levels, have resorted to imposing various levies on GSM operators in a bid to participate in the ‘financial windfall’ with which the sector is erroneously associated. Unfortunately, none of these agencies have bothered to actually evaluate the so-called huge profits and compare it to the average return on investments in order to correctly situate the ‘financial windfall’.
The four GSM companies are more capitalized than the entire banking and insurance industry put together, but does not have the same returns on investment. However, because of visibility and the ubiquitous nature of the networks, their barely reasonable profit, in comparison to the level of investment, attracts undue attention.
The attention leads all tiers of government to see GSM companies as ready sources for cheap revenue. Efforts by the NCC to correct this misconception are generally perceived as attempts by the industry regulator to ‘protect its turf’. Unfortunately, to justify the unconscionable fees they impose on GSM companies, these agencies of government imply that such sums are imposed as some kind of deterrent; to protect the people from the dangers associated with base stations. Where these agencies allege lack of standards, they do not bother to set any standards outside of mere imposition of a ludicrous fee regime.
Where operators direct them to existing standards set by the industry regulator or other relevant bodies such as the Federal Ministry of Environment, they plead a constitutional right to regulate without the commensurate responsibility that goes with best practices in regulation. They withhold necessary approvals for site build where the fees are not paid, and quickly grant them if fees are paid; implicitly accepting that safety was never an issue in imposing such fees. Aside from the adverse effects unnecessary levies impose on operators, especially as it raises costs which are normally transferred to the consumer, the actions of these agencies create an unnecessary fear of base stations in the general public further exacerbating the difficulties of site acquisition and build out.
One question that urgently requires an answer from these agencies, including Igbokwe’s LASIMRA, is; how does payment of huge fees remove the supposed health hazard associated with base station RF emissions? That is the key question!
