1.  INTRODUCTION

  Motorola is one of the world's leading providers of wireless communications, semiconductors, and advanced electronic systems, components and services. Its major equipment businesses include cellular phones, paging and data communications, two way radios, personal communications, automotive, defence and space electronics and computer components. 1998 revenues were $29.8 billion.

  Motorola Ltd, a wholly owned subsidiary, has been operating in the UK for 31 years and employs about 10,000 people in research, development, manufacturing and marketing. The company is a major UK manufacturer of cellular telephones and base stations, which it exports to a global market. Motorola Ltd had sales in 1998 of £3.3 billion and is one of the UK's top-ten exporters.

  Motorola has a long-standing commitment to public health and product safety, evidenced in part by worldwide leadership in RF measurement and support for biological research. Motorola has also encouraged other manufacturers, associations and governments to contribute to the existing scientific database and public policy foundation related to the safety of mobile communications.

  As a company that owes its growth and reputation over almost 70 years to its leadership in the development of the technologies at the heart of the information age, Motorola welcomes the opportunity to submit its views on this important matter.

2.  QUALITY AND OBJECTIVITY OF THE ADVICE PROVIDED AT PRESENT

  2.1  It is vital that the Government is provided with the best possible scientific advice on which to base:

(i)  public policy decisions.

(ii)  communications with the public about significant health risks.

(iii)  communications with the public about the mischaracterisation, misinterpretation or misunderstanding of risks.

  2.2  This is not a simple matter. Science by its nature is complex, and scientific findings may be difficult for the public to interpret. This has been the case with mobile phones and health.

  2.3  The Government has a responsibility not only to inform citizens about potential public health risks, but also to speak out when potential risks are mischaracterised or misunderstood. In contrast to the contradictions and controversy depicted by the media, scientific expert groups, government agencies and other authoritative bodies have concluded on numerous occasions that mobile phones and mobile phone antenna sites pose no known health risks.

  2.4  Motorola believes that the Government has sufficient resources to assess the quality of scientific advice on this matter. There are mechanisms in place to support the needs of policy makers and the public for scientifically accurate information on the safety of mobile phones and base stations.

  2.5  Foremost among them is the National Radiological Protection Board (NRPB), which has earned an international reputation for its expertise in this field. The NRPB scientific staff sometimes augments its own resources by consulting independent experts, and works closely with the Department of Health and the Health and Safety Executive on matters relating to the radio frequency (RF) exposure of workers and the general public.

  2.6  The NRPB serves the public interest in the UK and beyond in a number of ways: by conducting research, by evaluating research and by communicating the findings of such research to the public. The Government is well-served by the existence of an agency that can advise, evaluate and communicate with such authority and respect.

  2.7  At the same time, this is a global issue. The Government has access to the advice of various other national and international agencies and academic institutions around the world that, like the NRPB, monitor and evaluate scientific research related to the safety of mobile communications. These include such standing bodies as the World Health Organisation (WHO) and the International Commission on Non-Ionizing Radiation Protection (ICNIRP), which have issued scientific assessments similar in substance to those of the NRPB on issues related to the safety of mobile communications.

  2.8  The Government also can look to advice from special panels of international experts that may be assembled to evaluate the scientific research related to mobile phones and health. The decision by the Department of Health is not without precedent. Previous scientific reviews by similar panels commissioned by the European Commission and the Royal Society of Canada concluded that there was no substantive evidence of adverse health effects from mobile phones or mobile phone antenna sites.

  2.9  The Government need not rely solely on such official or formal sources of advice on this or any other scientific issue. It can call upon industry or others who have useful contributions to make to its deliberations on scientific research, public policy or regulation. In ALL cases, however, we believe the Government should subject the advice it seeks or receives to the same test of accuracy, objectivity and adherence to principles of scientific rigour and scrutiny.

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

  3.1  Motorola strongly endorses the approach advocated by the Office of Science and Technology in its note on "The Use of Scientific Advice in Policy Making", published in March 1997.

  3.2  Motorola wishes to draw the Committee's attention in particular to the advice in that note that Departments should draw on advice from outside the UK (para 6 (iii)), and should encourage a sound scientific basis for European Community decision-making (para 7). The mobile phone industry is global in its outlook and structure, draws on and contributes to a global science base, and advocates the development of global standards. It is essential that the global outlook of the industry is matched by the UK scientific advisory system maintaining a global perspective also.

  3.3  In its First Report of Session 1998–99, the Committee recognised that the level of scientific expertise in the civil service is a matter of importance (para 78). Motorola offers the view that, in the case of mobile phones, it considers the Departments, Agencies and independent bodies funded or part-funded by the Government (eg NRPB) with which it has had contact to be sufficiently expert to engage in scientific discourse of a penetrative nature.

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

  4.1  There are a number of ways the Government can assess the quality and relevance of scientific advice in order to achieve valid and supportable assessments of health risk.

  4.2  Procedures for assessing the quality of scientific information and advice have been established by the scientific community and are widely accepted by such organisations as the World Health Organisation, the International Agency for Research on Cancer and NRPB.

  4.3  The first imperative is to evaluate new findings or theories against the well-defined and well-accepted criteria for scrutiny used by such organisations as WHO, IARC and NRPB. These criteria include:

(i)  the use of completely objective and documented experimental techniques and methods using biological systems and controls appropriate to the human health endpoints being studied.

(ii)  objective data analyses and appropriate statistical methods; all relevant data should be considered.

(iii)  results must have a high level of statistical significance, tested against the above-mentioned criteria.

(iv)  results should be confirmable by researchers in other laboratories or at least consistent with the conclusions of similar experiments.

(v)  results should be interpreted first using accepted scientific principles before ascribing novel theories;

(vi)  finally, results must be relevant to human health.

  4.4  A second way the Government can assess the scientific information or advice it receives is to ask whether it is consistent with the judgements dispensed by other scientific bodies or government agencies around the world. The NRPB provides access by the Government to expert advice, which is well-integrated into that segment of the international scientific community that monitors and evaluates research related to the safety of mobile communications.

  4.5  Where the advice received is inconsistent with advice received from other sources, the Government may want to consider whether the advice in question meets the above-mentioned test of accuracy, objectivity and adherence of scientific principles. In the case of specific research findings, the Government will want to assure itself that the studies in question meet certain other criteria for quality, credibility and relevance. It also will want to have the results interpreted against the backdrop of established and accepted science.

5.  EXTENT TO WHICH THERE ARE GROUNDS FOR HEALTH CONCERNS

  5.1  Scientific research on the possible health effects of radio waves dates back more than 60 years. A large and ever-expanding body of scientific knowledge has provided scientific experts, standard-setting organisations, government agencies and health authorities with a sound basis for making judgements about the safety of mobile communications.

  5.2  Experts around the world have examined the research in this area on repeated occasions over many years. As the amount of research has grown, the fundamental conclusions of the scientific community and other authoritative groups continue to be that: there are no demonstrated health risks from the radio signals emitted by mobile phones or mobile phone antenna sites operating within established guidelines.

  5.3  Guidelines set in place by the NRPB and other agencies around the world provide a large margin of protection against any known adverse health effects. For years, scientists have been in general agreement about the threshold below which such effects from radiofrequency (RF) exposure are not known to occur. Standard-setting bodies have set exposure limits well below this threshold—by at least an order of magnitude—as a large margin of safety. Research continues to validate these limits as adequate and reliably protective of public health.

  5.4  Though the only established effects related to radiofrequency (RF) exposure are thermal (accompanied by temperature rise), the rigorous scientific reviews integral to the development of these guidelines also consider studies of possible athermal effects at levels below which thermal effects are known to occur. Because the results of such studies have been inconsistent and contradictory, with uncertain implications for human health, the athermal effects reported to date have been judged by the scientific and regulatory communities to be an inadequate basis for adopting health guidelines more stringent than those now in place.

  5.5  The strength of existing safety guidelines is rooted in the underlying science. In considering issues related to the safety of mobile communications, the Government can draw on a large body of scientific evidence that, when evaluated in its totality, demonstrates no health risks associated with these products and services.

  5.6  That is not to suggest that the research in this areas has produced uniform results. The scientific process, however, compels application of a "weight of the evidence" principle, which requires that new studies be evaluated against the backdrop of established scientific knowledge and experience.

  5.7  Only through a careful process of evaluation, validation and replication can reported effects become accepted as established or presumed fact. Reports of possible biological effects also must be evaluated for their implications, if any, to human health. In the instant case, this process has not established any adverse health effects at the exposure levels common to mobile phones or mobile phone antenna sites.

  5.8  Much research in this area has been done and much more is underway or planned. A significant amount of the research envisaged for the next few years will provide the International Agency for Research on Cancer (IARC), the World Health Organisation (WHO) and other authoritative bodies with further scientific data for future public health judgements about the safety of mobile communications.

  5.9  Motorola contributes to the process through an extensive programme of research carried out on its own and in conjunction with industry partners and others. This programme dates back many years and has made significant contributions to scientific understanding related to the safety of mobile communications.

  5.10  The Motorola programme is intended to challenge what is known and to enhance the foundation of credible science necessary for informed decisions by policymakers and the public. Motorola pursues these objectives by supporting focused, health-related research of the highest quality, performed by independent scientists at leading institutions and laboratories. In all cases, we always insist that whatever research is conducted on behalf of Motorola be submitted for publication in well-established scientific journals. This programme of sponsored research is augmented by a long-standing programme of in-house research that has earned Motorola worldwide recognition for leadership in RF dosimetry.

  5.11  In assessing reports of new research findings that may appear relevant to mobile phones and health, the Government must recognise the challenges inherent in conducting quality studies capable of surviving scientific scrutiny and enhancing the extant scientific database. Such studies typically require multidisciplinary scientific teams, strict laboratory controls, adequate funding and other measures to assure that the results are credible and meaningful.

  5.12  For reasons described above, Motorola believes there is a sound basis for public confidence in the safety of mobile communications. We believe this confidence is shared by most consumers. At the same time, we recognise that dramatic growth in the use of mobile phones has been accompanied by public questions and concerns about their safety.

  5.13  At Motorola, the safety and well-being of our customers is paramount. Motorola is sensitive to public concerns, regardless of the causes, and is responsive to questions that may arise about the safety of mobile communications.

  5.14  Some of this public concern can be traced to a lack of information. The public needs to be better informed about the deliberations that have taken place around the world about the safety of mobile phones. They need to be better informed about science and the scientific process to guard against unjustified alarm that may result from publicity about new research results that seem at odds with the scientific consensus.

  5.15  To the extent that there is public concern about the safety of mobile phones, it is no doubt fuelled by other factors as well: attitudes toward science, distrust of institutions, etc. To the extent that this is caused or compounded by inadequate access to objective information needed for informed judgements about the safety of mobile communications, industry, Government, the scientific community and the media all have roles and responsibilities in addressing this problem.

6.  OPPORTUNITIES FOR NEW TECHNOLOGIES TO REDUCE HEALTH RISKS

  6.1  As described above, numerous reviews by scientific experts, standard-setting organisations, government agencies and health authorities around the world have arrived at the same conclusion: the radio signals from mobile phones and mobile phone antenna sites pose no known health risk.

  6.2  Guidelines set in place by the NRPB and by other agencies around the world provide large margins of protection from any known adverse health effects from RF exposure. Research continues to reaffirm the adequacy of these guidelines as reliable guarantors of public health.

  6.3  The technologies of today meet established guidelines for safety. The technologies of tomorrow will as well.

7.  THE NEED FOR FURTHER RESEARCH

  7.1  The large extant body of scientific knowledge provides a sound basis for confidence in the safety of mobile communications. It also has identified a relatively limited number of scientific questions that need to be clarified through additional research so public health authorities have the basis they require for even more definitive judgements on this issue.

  7.2  Those needs are being addressed through current research and a building of international consensus on priorities for further research over the next few years. Motorola has actively promoted greater international co-ordination of research priorities and scientific activities through involvement with the World Health Organisation, NRPB and other agencies around the world.

  7.3  Research now under way or anticipated from programmes such as the one under consideration by the European Commission will provide adequate information to address the priorities that have been identified for meeting the needs of health risk assessments being conducted by the International Agency for Research on Cancer and the World Health Organisation.

  7.4  Mobile phone manufacturers and network operators will support the European Commission programme through a regime designed to ensure the quality and independence of the resulting research.

  7.5  Motorola believes industry can serve a useful, but limited, role in this regard—not in carrying out this research on its own, but in helping to fund and organise the best possible scientific teams to carry out priorities identified by the World Health Organisation and the European Commission.

  7.6  In the event that studies raise new questions that warrant further research, those issues will have to be addressed through a collaborative process much like the one in place today. Decisions on further research must be based on the specific requirements of scientists charged with public health assessments.

9 June 1999