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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O C. 20460
19 JUL
SAB-RAC-88-Q31
OFFICE OF
THE ADMINISTRATOR
Honoraole Lee M, Thomas
Administrator
U, S. Environmental Protection Agency
401 M Street, NW
Washington, DC 20460
Dear Mr. Thomas:
The Science Advisory Board's Radiation Advisory Committee has been
apprised of the Office of Radiation Programs' proposal to "defer" all
Agency involvement in nonionizing radiation after the Guidance to limit *
exposare (now being developed) Is issued. The intent is to phase out
such smaller programs and focus on larger tasks with perceived higher
priorities.
In its report on nonionizing radiation of January 31, 1984 (copy
attached) science Advisory Board recommended periodic review and
evaluation of new research, a strengthening of in-house' and extramural
research, and a continuation of the Agency's monitoring of arabient levels
and its technical support to other government agencies to assure eenplianee
with its Guidance.
Apart from one periodic review, the Agency has not found it possiole
to carry out any of these reccrrenenaations, nor is it likely to do so now,
despite renewed nationwide interest in the effects o£ nonionizing radiation
as a possible cancer promoter and the imminent issuance of a Guidance
that is to be implemented by other Federal agencies.
At its July 19 meeting, the'Executive Committee of the Science Advisory
Board joined with the Radiation Advisory Committee in- the recommendation that
the Agency must not .totally abandon its work in the area of nonionizing
radiation. This reconmendation is particularly relevant in the light of two
studies dealing with non<-ionizing radiation reported in the current issue of
the .American Journal of Epidemiology, which evidence both the continuing
interest in this field and the ambiguous nature of raost current data.
At a minimum, the Agency must continue to monitor research in this field
and provide technical support and assistance (including measurement capabilities)
to other government agenciesr as foreseen in EPA's Notice of Proposed
Recommendations, Federal Register 27318, July 30, 1986. Some agencies
have already expressed a need for such assistance in their implementation
ot and compliance with the forthcoming Guidance. It is imperative that a
viable Federal presence be maintainted in the area of non-ionizing radiation
and the support activity by the Agency will provide an inestimable service
in the public interest at a relatively small cost in budget and personnel.
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In owJef to clarify these issues, Che Board requests additional information
on the Agency's near- tern and long- tern plans for its own non- ionizing radiation
program and specific information about the current and planned levels of support
for non- ionizing radiation activities elsewhere in the Federal government.
Sincerely,
cc: R, Guimond
D. James
D, Barnes
Norton Nelson
Chairman
Executive Conroittee
Science Advisory Board
William J* Schull
Chairman
Radiation Advisory Comittee
Science Advisory Board .
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D,C, 20460
APRIL 25, 1§84
e or
THE AOIullMlSTW*T0«
Mr. William P. Ruckelshaus '
Administrator •
Environmental Protection Agency
Washington, n.t,. 20460
Hear Mr. Ruckelshaus:
The Science Advisory Roarri (SAP) has completed its review of the
Office of Research and Development's assessment document entitled Biological
Effects of 3adiofrequenc.y Radiation and is pleased to transmit its report
to you. An SAR Subcommittee, chaired hy IV, Charles Susskind of the University
of California at Berkeley, twice reviewed thp draft document and unanimously
concluded that it .represents an adequate- statement of the current scientific
literature and can serve as a scientifically defensible basis for the
'Agency's development of radiation protection guidance for use hy Federal
agencies to limit exposure of the general public to radiofreq.uency
radiation.
The enclosed report summarizes the Subcommittee's review process and
presents its major findings and recommendations. The SAR Executive Committee,
at its recent meeting of April 11 -12. fully endorsed the Subcommittee's
report and authorized its transmittal to you. Should you wish any further
SAB review of the radiofrequency issue.*,,!, am sure that the Board would he
pleased to address your request.
Sincerely,
Norton Nelson, Chairman
Executive Committee
Science Advisory Board
Enclosure
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UNIVERSITY OF CALIFORNIA, BERKELEY
BERKELEY • DAVIS - lAVIN'E » LOS A,xC£LEi • HIV£R$|OE • SAN OiEOO • SAX JTIUX'CISCO ifev'L. I. 4JNsJ SANTA BAllUARA • SANTA CHL'l
PROF, CHARLES SUSSKLND . 3]. january 1984
C-Cr COLLEGE OF '
ir, CA
Dr. Nor con Nelson, Chairman, ,SAB ,
Environmental Protection Agency
WASHINGTON DC 20460
Dear Dr. Nelson: .
The SAB Subcommittee on the Biological Effects of Radio! requency Radiation met on
22-23 September 1983 and on 24-25 January 1984 to review the report on Biological
Effects of Radiofrequency Radiation produced by a team led by J. A. Elder and D. F,
Cahill at EFA's Health Effects Research Laboratory in Research Triangle Park, N.C.
The Subcommittee asked for changes in the organization and wording of the report »
virtually all of which have been accommodated in the final version. Accordingly,
the Subcommittee concludes that the repqrt__is_ an adequate review of the scientific
literature' and can serve as the basis for the development of radiation protection
guidance for use by Federal agencies to limit exposure o£ the general public _to
ra'diof requeney_ jcadiation. The Subcommittee also concludes that the EPA team has
done a splendid job in producing the report arid in responding to the Subcommittee's
requests for amendments;, its members, and especially team leader Joe A. Elder, are
to be commended.
The Subcommittee has asked me to make clear that its conclusion is limited to the
review of the scientific literature; it does not extend to prior approval of any
standards EPA may base on this material. In addition, the Subcommittee wishes to
make the following recommendations,
1. The process of reviewing the scientific literature should go on within EPA,
so that there is at least one government agency that uses its own professional staff
to keep abreast of developments in this field/ That is not to. say that the agency
should not avail itself 'of outside advice from time to time, for instance by
periodically constituting a review committee to monitor its own efforts.
2. If significant new results appear between such periodic reviews (which could f.
be scheduled^ say, every two years) , they should be evaluated for pertinence and used
for revision of exposure standards as appropriate- It is most unlikely that any
standard based on the present effort will remain appropriate for all time; a standard
is inherently dynamic, since it reflects knowledge at the time of promulgation.
3. EPA should continue and strengthen its program of extramural research, and also
its in-house research on the health effects of radiofrequency radiation, not only 'to
keep abreast of the field (Item 1 above) but also because the research itself is invalu-
able to the nation, as attested by the fact that a considerable part of the scientific
results. reported in the present review derives from work done at EPA's own laboratories.
4, The agency should provide technical support to- other government agencies to help
then in assuring compliance with EPA standards.
5. The agency should continue its unique and valuable service in monitoring ambient
levels (and studying population exposures) throughout the USA, and in characterizing
the environment, including such problems as may arise from modes of modulation imposed
on radiofrequency sources; the rapidly changing picture in telecommunications and data
transmission alone would warrant continuation of this service,
6. The Subcommittee draws special attention to certain research topics that may not
have progressed far enough to be of use in rule making at present but may become
significant in the near future. Among them are the following,
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Siisskind to Nelson, 31 Jan 84, p. 2
a* Effects of modulation imposed on radio frequency carriers, particularly modulation
at 'very low frequencies, on biological specimens exposed to very low power densities-
b. Effects of chronic vs acute exposures, and of partial-body vs whole-body
exposures.
c. Effects of exposure to pulsed sources of very high peak power vs sources that
ate adequately characterized by average power,
d. SynergistiC effects of radiofrequeney energy with other physical and cheaical
agents.
e» Validation of recent: results with regard to mutagenie and similar effects
observed at low power densities.
f - Evaluation of the thermoregulatory capability and concfotnitant physiological
processes of various populations exposed under extreme environmental condtions.
Sincerely,
Charles SuSskindu Chairman
SAB Subcommittee On the
Biological Effects of IF Radiation
cc; Subcommittee members
Drs- Elder, 'Seba» Yosie
Mr . Janes
CS:t
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