1.  INTRODUCTION

  1.1  The Federation of the Electronics Industry (FEI) is the voice of UK Electronics for communications, IT, components, defence electronics and office technology. FEI plays a leading role in political and regulatory issues to ensure the future growth of its markets, and is recognised by DTI as the leading trade association for the electronics and office technology sectors.

  1.2  This Memorandum represents the views of the FEI Public Radio Telecommunication Committee, whose membership includes BT, BT Cellnet, Cable & Wireless, Ericsson, ICO Global, Lucent Technologies, Motorola, NETRO Corporation, Nokia, One 2 One, Orange, Panasonic, Philips, and Simoco; leading companies in the UK mobile phone Industry ("the Industry"). The Committee is responsible within FEI for issues affecting the Industry.

  1.3  The Industry currently employs over 100,000 people and contributes around £5 billion to the UK's GDP.

  1.4  There are now 15 million mobile phone users in the UK—that is 25 per cent of the population.

  1.5  The UK mobile market grew by 54 per cent in 1998. In the first quarter of 1999, the Industry acquired almost 20,000 customers every day. It is currently the third largest wireless market in Europe.

  1.6  The Industry is committed to the development of new competitive mobile telephony systems that will enable it to deliver significant economic, social and public policy benefits to the UK in the Information Age.

  1.7  Any queries concerning this Memorandum should be addressed to Tom Wills-Sandford, the FEI Director of Information and Communications Technology, on 0171-331 2010.

2.  SUMMARY—MAIN POINTS OF FEI'S EVIDENCE

  2.1  The Industry welcomes the inquiry into the Scientific Advisory System. The Industry cares about its customers and is responsive to any public concern about the possible adverse health effects from mobile phone use and operation of base stations. The Industry is committed to addressing these concerns and acting responsibly by providing information to its customers, Government and other stakeholders.

  2.2  If the public is to have confidence in Government policy, people need to be certain that Ministers receive independent, up-to-date, expert advice on this issue. Policies designed to protect the public should be based on sound scientific advice relating to established adverse effects on human health.

  2.3  The scientific peer review process is essential if the process for public policy development is not to be undermined. Sound science is work that has stood up to detailed scrutiny through independent assessment, and which contributes to new knowledge and understanding. The Industry supports open debate and transparency of peer reviewed scientific research, irrespective of its findings.

  2.4  The National Radiological Protection Board (NRPB) has a statutory responsibility to provide advice and information to both the Government and the public. It is independent of both Government and Industry, and its staff includes internationally renowned experts who have a great deal of experience on health issues of interest to the Committee. The Industry is confident that the NRPB can provide that advice, and that the guidelines it sets are based on the most up-to-date sound science. However, the Industry agrees with the NRPB that more research, co-ordinated on a global basis, is needed.

  2.5  The NRPB has stated (response statement No R3/99) "At present, the international consensus in the world wide scientific community is that there is no demonstrable evidence of a health risk." and the Industry entirely accepts this position.

  2.6  Thanks to years of research, much is known about the health effects of radio waves. The NRPB guidelines are set to ensure that public exposure to Radio Frequency (RF) emissions from the use of mobile phones and from operational base stations are well below the level of established adverse health effects. Current products meet the requisite standards and exposure guidelines, and future products will continue to meet the standards and guidelines.

3.  QUALITY AND OBJECTIVITY OF ADVICE PROVIDED AT PRESENT

  3.1  The Industry welcomes the inquiry into the Scientific Advisory System. The Industry cares about its customers and is responsive to any public concern about the possible adverse health effects from mobile phone use and operation of base stations. The Industry is committed to addressing these concerns and acting responsibly by providing information to its customers, Government and other stakeholders.

  3.2  If the public is to have confidence in Government policy, people need to be certain that Ministers receive independent, up-to-date, expert advice on this issue. Policies designed to protect the public should be based on sound scientific advice relating to established adverse effects on human health.

  3.3  The NRPB has a statutory responsibility to provide advice and information to both the Government and the public. It is independent of both Government and Industry, and its staff includes internationally renowned experts who have a great deal of experience on health issues of interest to the Committee. The Industry is confident that the NRPB can provide that advice, and that the guidelines it sets are based on the most up-to-date sound science. However, the Industry agrees with the NRPB that more research, co-ordinated on a global basis, is needed.

  3.4  The Government and the Industry face a difficult challenge to communicate scientific evidence to the general public. One of the problems with public health issues is that the perception of the issue is not necessarily objectively derived. The credibility of the "messengers" is as important as the actual message being delivered. The Industry believes that ways need to be found to communicate scientific evidence and effectively inform the public, and that this duty lies with the Government, their advisers and the media.

  3.5  The Industry suggests that the NRPB reviews its communications strategy to set up an effective mechanism to increase its role in informing the public. Making decisions on science is only part of what is required, communicating effectively and with integrity is also increasingly important.

4.  SUITABILITY OF CURRENT PROCEDURES AND STRUCTURES FOR OBTAINING GOOD QUALITY SCIENTIFIC ADVICE

  4.1  Industry believes it is important that judgements about mobile phones and base stations are based on the totality of science rather than drawing conclusions from individual studies. That is why we welcome the recent Government announcement to set up an NRPB Expert Working Group to review all research in this area.

  4.2  The Industry believes that the Government should integrate the overall UK research programme into the international programme developed by the World Health Organisation (WHO).

  4.3  UK Industry has helped to establish processes within the FEI, the Mobile Manufacturers' Forum (MMF) and the GSM Association to review research being conducted in the UK and around the world.

5.  PROCESSES FOR ASSESSING SCIENTIFIC ADVICE IN POLICY MAKING AND REGULATION

  5.1  The Industry endorses the current process which has statutory bodies such as the NRPB responsible for setting RF exposure guidelines, and international standards organisations such as the European Telecommunications Standards Institute (ETSI) responsible for developing the technical standards for new wireless communication systems and services.

  5.2  The Industry welcomes greater discussion with Government on the processes by which scientific advice is assessed, and in the implementation of regulations.

  5.3  The Government must continue to guard against public policy decisions or public statements based on reported research that has not been subjected to expert evaluation and published through the accepted expert scientific consensus process.

6.  EXTENT TO WHICH THERE ARE GROUNDS FOR HEALTH CONCERNS

  6.1  Thanks to years of research, much is known about the health effects of radio waves. The NRPB guidelines are set to ensure that public exposure to RF emissions from the use of mobile phones and from operational base stations are well below the level of established adverse health effects. Current products meet the requisite standards and exposure guidelines, and future products will continue to meet the standards and guidelines.

  6.2  Despite the international consensus in the world wide scientific community, the industry recognises that our customers have raised questions about the possible adverse health effects of mobile phones and base stations. Our customers' concerns are our concerns, and the Industry strives to address any questions that may arise.

  6.3  Industry believes that the public's concern over possible health risks is partly determined by the public's perception of risk. The issue of mobile phones and health involves complex science, and although there is a wealth of science around the world there is still a need to establish the roles and responsibilities for communication by the scientific community, Government, Industry and the media. All parties must take a responsible approach in the communication and reporting of scientific studies.

  6.4  The Industry has created a number of documents that answer questions on mobile phone health concerns, base station siting and interference issues in an objective and factual manner.

7.  OPPORTUNITIES FOR NEW TECHNOLOGIES TO REDUCE HEALTH RISKS

  7.1  The NRPB has stated (response statement No R3/99) "At present, the international consensus in the world wide scientific community is that there is no demonstrable evidence of a health risk," and the Industry entirely accepts this position.

  7.2  Mobile phones have been designed to operate below the NRPB guidelines, and typical exposure from base stations is hundreds of times below the guidelines in areas where the general public have access. Current products meet the requisite standards and exposure guidelines, and future products will continue to meet the standard and guidelines.

  7.3  The development of new technologies, together with the continual review of good scientific research and exposure guidelines, all help to keep any risk as close to zero as possible.

8.  NEED FOR FURTHER RESEARCH

  8.1  The scientific peer review process is essential if the process for public policy development is not to be undermined. Sound science is work that has stood up to detailed scrutiny through independent assessment, and which contributes to new knowledge and understanding. The Industry supports open debate and transparency of peer reviewed scientific research, irrespective of its findings.

  8.2  The mobile phone industry is a global industry, and there have been many hundreds of scientific studies undertaken since the inception of RF communications. The research programme is ongoing, and there are currently numerous studies underway world-wide which are funded by Industry, and many further funded by Government and other sources. All good quality, peer reviewed results are in the public domain.

  8.3  Industry funded research is conducted by expert, independent research bodies, demonstrating the Industry's openness in addressing this issue. The research it funds is carried out to the highest standards. The Industry does not seek to influence the results of these research projects.

  8.4  The WHO and EU both have major research and risk evaluation programmes related to mobile communications. Other organisations sponsoring research in this area include Wireless Technology Research (WTR) in the USA, Forschungsgemeinschaft (FGF) in Germany, and the RF ElectroMagnetic Energy (RF EME) Program in Australia. All of these organisations receive Industry funding but operate with independent management structures. In the UK, studies are being carried out at the Universities of Birmingham, Bradford, Bristol and Surrey.

  8.5  The Industry supports efforts to expand scientific knowledge in the field of mobile telephony, both through its own research and through co-operation with leading scientists and organisations around the world. The Industry believes that research, whether funded by the Industry, Government or other sources, should be co-ordinated on a global basis.

  8.6  The Industry continues to fund research because we believe that there can never be too much good, credible research. We are committed to supporting research into this issue on an ongoing basis and to ensure that the results are available to the public.

  8.7  In addition to scientific research, the Industry supports non-scientific research into areas such as attitudes and perception.

9 June 1999