INTRODUCTION

  1.  The Vodafone Group is one of the world's leading providers of mobile telecommunication services. The Group now has interests in 12 countries outside of the UK and the number of subscribers connected to Vodafone's cellular networks worldwide (on an equity-adjusted basis) exceeds 10 million.

  2.  Vodafone's principal business in the UK is the operation of its analogue and digital radio networks and it is one of four cellular operators. It currently provides service to over five million customers through a network of over 5,000 radio base stations across the UK.

  3.  Customers are connected to Vodafone's analogue and digital networks through service providers or retailers who also sell or rent handsets. The Group has its own wholly owned service provision companies with more than 240 retail outlets.

  4.  The Vodafone Group announced in January this year that it is to merge with AirTouch Communications Inc, an international mobile business based in the US. The merger will create Europe's most valuable telecommunications group and the world's largest, and first truly global, mobile phone company. The group will have a market capitalisation of around £70 billion, operations in 23 countries and over 23 million customers. This will make it the second or third largest company in the UK.

SUMMARY

  5.  The Vodafone UK network is designed to comply with the guidelines of the National Radiological Protection Board (NRPB), an independent Government body part funded by the DoH. Radio base station emission levels are significantly below these guidelines in areas where the general public have access. In these areas, the latest scientific review concludes that "neither biological nor adverse health effects are likely to occur". In areas very close to antennas, but within which the guidelines may be exceeded, there are appropriate warning signs that also give procedures for switching off transmission when access is necessary.

  6.  Handsets are designed to comply with NRPB and international guidelines when operating at their maximum transmitter power output level. During each call, the network instructs each handset to reduce its transmit power to the minimum required for service thereby minimising the user's exposure to Radiofrequency (RF) fields. The greatest reduction in handset transmitter power occurs in areas close to a radio base station.

  7.  The NRPB reviews its guidelines to take into account the world scientific consensus and the results of new peer reviewed published research. Vodafone supports calls for further high quality research in accordance with the World Health Organisation (WHO) priorities and will continue to provide arms length funding to appropriate independent research bodies.

  8.  Vodafone suggests that a central body should be established which should be seen to be independent of industry influence and which should co-ordinate new research proposals, allocate and manage their funding and communicate a balanced view of the scientific consensus to the Government, industry and the general public. This could be achieved by further extending the role of the NRPB and the expert working group recently announced by the Minister for Public Health. Vodafone will of course also continue to help in this public education process.

THE QUALITY AND OBJECTIVITY OF THE ADVICE PROVIDED [TO GOVERNMENT] AT PRESENT

  9.   Vodafone considers that the advice given by bodies such as NRPB, DTI and Health & Safety Executive is of good quality and is objective. The NRPB advice is published and is updated based on their review of the current set of peer reviewed published scientific papers.

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

  10.  Vodafone believes the NRPB to be fully aware of all relevant research and the NRPB has also contributed to the identification of research requirements on a European and global basis.

  11.  There is, however, no independent UK body currently operating as a focus for reviewing individual proposals for new research and managing the funding of such research. Without such a body, industry and Government have to make their own choices on what research projects to fund and this does not maximise the public confidence in the results of research. This could be achieved by further extending the role of the NRPB and the expert working group recently announced by Tessa Jowell MP, the Minister for Public Health.

THE PROCESSES FOR ASSESSING SCIENTIFIC ADVICE IN POLICY MAKING AND REGULATION

  12.  Vodafone welcomes the opportunity to contribute to a review of these processes.

  13.  In such a complex area, it is important that the processes ensure that the Government acts only in response to a full assessment of science and is not forced to take a precipitate position based upon an incomplete set of evidence.

  14.  The EU is currently finalising a council recommendation on a limitation of exposure of the general public exposure to electromagnetic fields. As far as Vodafone is aware no statements have been made regarding how this will be incorporated into UK guidelines from the NRPB, DTI, DoH, DETR or Health and Safety Executive.

  15.  Inevitably, there are different priorities for each Government Department and it is not clear to industry how these are balanced with external contributions to form a consistent Government position, eg the consultation on land-use planning and electromagnetic fields (EMF's). Furthermore, it is also unclear how such positions are to be harmonised between devolved regions.

  16.  An aspect that needs to be urgently addressed is the communication of the science in order to provide a balanced view for the general public, industry and Government. A central body that can be seen to be independent of industry influence could facilitate this communication. This could well be the same body as in Paragraph 11 above.

THE EXTENT TO WHICH THERE ARE GROUNDS FOR HEALTH CONCERNS

Vodafone's understanding of how the standards/guidelines are set

  17.  Many countries and international organisations have set standards/guidelines with respect to the protection of human health from any known harmful effects from electromagnetic fields eg NRPB, International Commission on Non-Ionising Radiation Protection (ICNIRP). To produce these standards/guidelines, eminent scientific panels consider many published papers and assess them for credibility, paying particular attention to the peer-review principle.

  18.  To date, they have all concluded that the only substantiated harm comes from excessive heating of the human body and have decided to ensure this heating by electromagnetic fields is restricted to less than one degree centigrade. They also currently conclude that there is insufficient evidence to justify further guidance based on non-thermal effects.

  19.  To enable adherence to the restriction it is necessary to convert this temperature rise to other physical quantities, primarily the "Specific Absorption Rate" or "SAR". This is the energy absorbed by a mass and may be expressed in units of Watts per kilogram (W/kg). When converting temperature rise to SAR a safety margin is added which, in the first instance, is generally 10 times. The human being can efficiently dissipate this energy, particularly if only one part of the body is exposed. Thus, the temperature rises slightly in the first six minutes of exposure, but is then quickly stabilised, ie prolonged exposure does not result in a further temperature increase.

  20.  SAR is a difficult value to measure in operational conditions, so other "investigation" or "reference" levels are derived and additional safety margins are applied. These quantities are field strength values in the space in which a human being might be found. At cellular frequencies, these may be expressed in units of power flux density (Watts per square meter) or electric field strength (Volts per meter).

  21.  The main difference between the standards/guidelines from different organisations is the safety margins they apply for sub-sets of the populace. Some make a distinction between "General Public" and "Occupational" exposure. Others distinguish between adults and children. The EU is currently preparing guidelines to address the general public exposure to electromagnetic fields.

  22.  In 1993, the NRPB published their guidelines in the "Board Statement on Restrictions on Human Exposure to Static and Time Varying Electromagnetic Fields and Radiation". The NRPB still supports the conclusions of these guidelines today, taking into due consideration peer-viewed scientific studies published since 1993.

Vodafone's understanding of the research

  23.  Vodafone considers the NRPB and international expert reviews of the entirety of science to form an objective view of the current understanding of research conclusions. In co-operation with other operators, handset manufacturers and national bodies, Vodafone monitors many research papers that are published on the health effects of electromagnetic fields and also participates in various conferences and workshops.

  24.  The expert reviews consider the wide range of studies performed throughout the world and over a long period of time. The NRPB guideline document has 436 references; most of which have been published in recent years but one dates back to 1896.

  25.  Paragraph 93 of the current NRPB guideline documents states:

"Conclusions: Many experimental data indicate that RF and microwave radiation are not mutagenic, consequently they are unlikely to act as initiators of carcinogenesis; in the few studies carried out so far, evidence of an enhancement of the effect of spontaneous or chemically induced tumours has been sought. The results obtained are equivocal, although tumour progression may be enhanced at levels that may be thermally significant. In vitro studies have described enhanced cell transformation rates in a mouse fibroblast cell line after exposure to microwave radiation followed by treatment by the chemical promoter TPA, but the evidence that microwave radiation affects the process of carcinogenesis is not compelling. The lifetime exposure of rats to low level microwave radiation appeared to have no other effects on health or cause of death."

  26.  One of the most recent authoritative documents on the subject comes from Royal Society of Canada entitled "A review of the Potential Health Risks of Radiofrequency Fields from Wireless Telecommunication Devices" released in May 1999. This includes in its executive summary [pages 3, 3rd para] the paragraph:

"Scientific studies performed to date suggest that exposure to low intensity non-thermal RF fields do not impair the health of humans or animals. However, the existing scientific evidence is incomplete, and inadequate to rule out the possibility that these non-thermal biological effects could lead to adverse health effects. Moreover, without an understanding of how low energy RF fields cause these biological effects, it is difficult to establish safety limits for non-thermal exposures."

  27.  In the same review [page 10, last para] the Royal Society of Canada clarifies its position on base stations:

"Because of the low field strengths associated with public exposure to RF fields from wireless telecommunications base station transmitters, neither biological nor adverse health effects are likely to occur."

What Vodafone is doing to address and understand health concerns

  28.  The UK cellular operators, with British Telecom and Cable & Wireless, have formed a Mobile Telecommunications Advisory Committee (MTAC). This committee is supported by the Federation of the Electronics Industry (FEI) and will facilitate information exchange between operators, the general public, media and Government. MTAC will also help operators to understand and support quality research and help address the public perception of the scientific consensus.

  29.  Vodafone has established a working group, chaired by a Director, which meets regularly to consider all developments. If we become aware of any research that alters our basic position, we will make that information public.

  30.  As part of its ongoing communication strategy, Vodafone is currently finalising a leaflet designed to further inform the public on the issues relating to radio base station emissions. This will augment the 2nd edition of the Environmental Handbook published last year. The FEI and many manufacturers and other operators have published information. This industry material often references sources such as the NRPB and ICNIRP web sites to ensure transparency and independence of the scientific consensus.

  31.  The Vodafone network is designed to comply with the advice of the NRPB, UK health and safety guidelines and the DTI license conditions on maximum transmit power for each carrier. In areas where people live and work, the field strengths from base stations are significantly lower than the NRPB guideline levels eg for a typical 15m high pole mast, someone standing right at the base will be exposed to less than 1/10,000th of the NRPB guidelines. Scientific opinion is that adverse health effects are not likely to occur (Paragraph 27).

  32.  In the vicinity of base station antennas, there are limited areas that are marked by warning signs within which the NRPB "investigation levels" (Paragraph 20) may be exceeded. Procedures are in place to limit access to such locations and to switch off the transmissions when people need to enter these areas.

  33.  The EU is currently finalising a council recommendation on the limitation of exposure of the general public to electromagnetic fields. Vodafone expects to conform immediately to this recommendation for all new radio base station sites. We believe that most of the existing sites already comply, however all sites will be checked and modified if necessary as soon as practicable, but no later than 18 months after publication of the recommendation.

  34.  There are occasions where special care is needed due to the potential interaction of RF fields with electronic devices in a way that may indirectly impact upon human health. In the case of hospitals, site surveys are conducted to ensure that field strengths in sensitive areas are at least three times lower than the levels in the current EU EMC directive. If there are likely to be flammable atmospheres or electro-explosive devices in the vicinity of a base station, an assessment is made to ensure compliance with the appropriate BSI standards on safe field strengths.

  35.  The GSM standards define the maximum power that may be transmitted by a handset. However, as a user gets closer to a radio base station, the handset transmit power is reduced in steps via network instructions to the minimum required to maintain the communications link. Without such power control, the excess RF power from the handset could cause interference to other users on the same radio frequency in nearby cells.

  36.  The commercial success of cellular telephony has meant that increasing numbers of radio base stations are required in order to provide the capacity to maintain acceptable quality of service. In many areas, this has reduced the average distance between users and the nearest radio base station with a consequential reduction in the average RF power transmitted by handsets. There is therefore a synergy between the commercial requirement to extend capacity to maintain a high quality of service and a desire to reduce the average RF power from handsets.

Vodafone participation in relevant research

General

  37.  Research is best conducted by independent experts under a funding framework that ensures that the research is recognised to be fully independent of any influence from industry. The current prime focus for research is to establish if there are any non-thermal adverse health effects at the exposure levels typical for handset use. Unless such research points to a specific line of investigation, research at the lower exposures seen from radio base stations is unlikely to be productive and may use resources best used for the prime focus. Therefore, Vodafone does not conduct its own research but supports quality research funded and organised through independent bodies.

  38.  This type of research is global in nature. The selection of appropriate future studies needs to take into consideration all peer-reviewed published research and current work in progress.

Vodafone's past involvement

  39.  Vodafone helped to fund and participated in a UK "LINK" research project. LINK is a scheme by which Government, Universities and Industry co-operate in a research project. The particular project in question was called IBREHT (Interaction of the Body with the Radio Emissions from Hand-held Transceivers). The purpose of the project was to determine the SAR in the human head from a handset and a final report was published in 1997.

  40.  Most of the world's operators using the GSM system are party to a Memorandum of Understanding which formed the GSM Association. This Association established a subgroup called the EMC and Bio-effects Review Committee (EBRC) which Vodafone chaired until 1998. One of the most important tasks of this group was to consider the research that should be funded. It contributed funding to the WHO International EMF project (Paragraph 55). It also played an active role in supporting the commencement of a European research project that is now likely to go ahead as part of the EU Framework Program 5.

Vodaphone's current and planned involvement

  41.  In the UK the MTAC (Paragraph 28) procedures, which lead to a recommendation to fund a specific research proposal, involve the scientific and management review of the proposals. Examples of the review criteria are that:

—  research should ideally fit the current WHO priorities;

—  research should be of high scientific quality;

—  results should be scheduled for peer-review and publication;

—  an independent management structure should exist; and

—  the protocol has a high probability of answering the hypothesis.

  42.  Vodafone, and the other UK operators, have recently agreed to part-fund the UK Adult Brain Tumour epidemiological study under the financial management of the British Occupational Health Research Foundation.

  43.  Other requests for UK research funding have recently been put to MTAC for consideration. However, it would be preferable if there was a central UK body where research proposals could be assessed and funding allocated in a manner seen to be independent from such direct industry review.

  44.  Each Vodafone Group Plc operator individually supports research on a global basis by contribution to the GSM Association funding. The GSM Association is continuing its provision of funding for the WHO International EMF project and has agreed in principle to work with the Mobile Manufacturers Forum to ensure that a set of research proposals is put to the EU Framework Program 5 for funding.

  45.  The GSM Association's planned research funding for the next five years is over £3 million, of which the combined Vodafone AirTouch group and its international associates expect to contribute approximately £400k.

  46.  Vodafone Limited has spent some £250k over the last five years on the RF Health and Safety issue and has already committed £162k over the next five years to external research.

  47.  Vodafone's international companies and its associates also contribute to various national research programs.

THE OPPORTUNITIES FOR NEW TECHNOLOGIES TO REDUCE HEALTH RISKS

  48.  We are confident that mobile phones are compliant with the current guidelines protecting people against adverse health effects. The potential impacts of some technology developments are assessed below.

  49.  Handset antenna design: It is possible with advances in antenna design to direct more of the signal towards the radio base station. By so doing the handset's output power need not be so great and the SAR in the head will be reduced. This can be achieved, for example, by having the antenna further from the head and by having the power radiated directionally away from the head.

  50.  Hands free accessory: This consists of an external microphone and earpiece that connects to the handset. It enables the handset to be used away from the head, which may be perceived by some users as giving additional peace of mind. It reduces the energy dissipated in the head and potentially allows the handset to operate at a lower transmit power (Paragraphs 35 and 36). Similar accessories can enable hearing aid wearers to use handsets.

  51.  RF Shielding devices: There are devices on the market that put an insulating shield over the body of the handset and some even put a partial short on the antenna. These devices attempt to reduce the signal from the handset, but the UK cellular networks control the handset transmit powers to be just adequate to access the network to compensate by increasing their transmitter power output up to a fixed limit (Paragraphs 36 and 36) and thus more heat is generated.

  52.  Data: New high speed GSM data services will result in an increase in the average power transmitted by handsets using those services due to more than one time slot being transmitted by the handset. However, this will primarily apply to non-voice services where the handsets are unlikely to be located in close proximity to the head/body.

  53.  Third Generation: Vodafone has been active in the development of global standards for the next generation of mobile phones. These standards are expected to be frozen by the end of 1999 with commerical launch in 2002. The proposed transmission system is significantly different from those currently used, with the mobile transmit power level being adjusted hundreds of times per second to ensure an absolute minimum required for communication at all times. It is expected that the average power transmitted will always be less than the maximum GSM handset power. In areas of good coverage, the power will be substantially less, due to the fast power control. It should be noted that, as in the case of GSM (Paragraphs 35 and 36), the lowest handset powers will be achieved where there is a high concentration of radio base stations.

THE NEED FOR FURTHER RESEARCH

  54.  Government and industry must base their actions on balanced scientific analysis of an entirety of quality peer reviewed studies. The general scientific consensus is that more research is currently required before we can rule out the possibility of adverse health effects that may require the guidelines to be modified. It is with this background in mind that Vodafone is supportive of the co-ordination being performed by the World Health Organisation (WHO).

  55.  In 1996 the WHO established its International EMF project. This project has made recommendations for further research needed to address an EMF health risk assessment. During November 1996 the EC published its Experts Report, "Possible health effects related to the use of radiotelephones—Proposals for a research program by a European Commission Expert Group."

  56.  In summer 1998, the industry established the Research Planning Committee (RPC) comprising membership from research scientists and industry. The objective of the RPC was to assist industry in developing a research program. Over a six-month period RPC consulted world-leading experts and held workshops in order to develop the research plan.

  57.  During December 1998, the RPC reported to the WHO research co-ordination meeting the following research requirements:

Priority 1: Epidemiological study

—  IARC multiple-centre case-control study with the following end points:

—  brain tumours.

—  salivary gland tumours, acoustic neuromas and other head and neck tumours.

—  leukaemia and lymphomas.

Priority 2: Cancer Related Animal Studies

Priority 3: Non-Cancer studies

—  Human: Headaches, blood pressure, memory, hearing, sleep

—  Animal: Replicate earlier behaviour studies that have indicated possible effect.

Priority 4: In Vitro Studies

—  Replication of earlier positive in vitro studies.

  58.  The above priorities have been adopted as the current working basis for the UK MTAC considerations of funding and by the GSM Association. They are also fully reflected in the proposals, supported by operators and manufacturers, being submitted to the EU for Framework Program 5 funding.

  59.  The research to be supported includes the International Agency for Research on Cancer (IARC) multi-national epidemiological study, studies using humans, studies using rodents and in vitro studies. This program should go a long way to address the majority of outstanding WHO-identified research requirements (Paragraph 57) and enable comprehensive risk assessments to be prepared. In 2003, the IARC will evaluate the carcinogenicity of RF fields and in 2004 the WHO will assess the non-cancer health risk of RF fields.

9 June 1999