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Sent via Email on 21st November 2025

Response to Sefton Council: Clarification Requested on RF EMF Governance and Legal Duties

For the attention of the Chief Legal Officer, Sefton MPs and Councillors,

Thank you for your letter dated 28 October 2025 and for providing the Council’s position on RF EMF and public health. For transparency, and in recognition that decision-making on these matters ultimately rests with Sefton Councillors and our Members of Parliament, this response is also shared with them. Given the Councillors’ role as the final line of accountability for the constituents of Sefton, it is essential that they are fully informed of the evidence and concerns presented. This correspondence builds on our original letter to Sefton Council, which can be referenced in full here: https://radiationresearch.org/radiation-research-trust-letter-sent-to-sefton-council-supporting-sefton-residents-on-5g-health-concerns/.

We are disappointed that the Council claims the right to decline further responses where it judges no new matters are raised, effectively closing the door on independent scientific and public health input and concerns.

While the Council cites the WHO‑commissioned Karipidis et al. (2024) review via UKHSA to support claims of safety, the review itself is provisional. The authors use conditional language, stating that RF exposure “likely does not increase the risk” and noting that the WHO task group is still drawing overall conclusions. This cautious framing underscores that the review cannot be taken as a definitive statement of safety. When combined with independent critique, primary animal and human evidence, and rising real-world cancer trends, it is clear that reliance on this review alone is insufficient to justify assurances of safety or to preclude precautionary governance.

Sefton Council’s reliance on Karipidis et al., while repeating ICNIRP’s criticisms of the NTP and Ramazzini studies from the same collection of WHO reviews, ignores core evidence, creates a clear scientific contradiction, and undermines public confidence. Relying solely on provisional WHO, UKHSA, and ICNIRP assessments to justify 5G deployment is ethically questionable, given robust independent critiques, primary research showing potential harm, and clear evidence of rising cancer incidence.

Introduction: Rising Cancer and Public Health Context

Cancer incidence is rising across all age groups, highlighting a serious public health concern. While WHO‑commissioned studies on RF EMF exposure form part of the available evidence, independent scientific critique and real-world data indicate that claims of “safety” cannot be assumed, and precautionary governance is essential.

Primary WHO Commissioned Evidence Demonstrates Cancer Signals

The WHO commissioned systematic reviews include primary studies showing cancer-related outcomes:

  • ◆ Mevissen et al., 2025: increased cancer in male rats
  • ◆ National Toxicology Program (NTP), 2018: clear evidence of carcinogenicity
  • ◆ Ramazzini Institute, 2018: brain and heart tumours at non-thermal exposure levels

These studies are two major independent research programmes conducted in separate laboratories in the United States and Italy, demonstrating clear evidence of carcinogenicity. The NTP studies underwent rigorous external review by eleven independent experts who confirmed the quality, reliability, and robustness of the research. These studies are therefore far from “limited” and should carry significant weight in public health considerations.

The primary data within WHO reviews indicates clear risk and should be considered in public health and planning decisions. While the Council notes that extrapolation to humans is complex, this uncertainty strengthens the need for the Precautionary Principle. Regulatory and public health authorities routinely rely on well-conducted animal studies to identify potential human health hazards, including cancer and other toxic exposures. The presence of cancer signals in animal studies is considered a valid warning, and uncertainty about exact human effects strengthens rather than diminishes the need for precautionary action to protect residents, especially vulnerable populations such as children, pregnant women, and those with chronic health conditions.

UK‑registry data (ONS / NDRS) show steadily rising cancers in those aged 15–24, and RCPCH reports a 15% increase in childhood cancer since the 1990s. Such real‑world trends reinforce the need for precautionary governance rather than assumptions of safety.

Rising Incidence of Brain Tumours in England and Human Evidence

UKHSA cites Karipidis et al. (2024) to claim RF exposure “likely does not increase the risk,” but rising brain tumour incidence and independent research highlight ongoing potential risks, reinforcing the need for precautionary measures.

Recent research demonstrates a worrying increase in the deadliest form of brain tumours in England. Philips and Henshaw (2018) report a significant upward trend in glioblastoma multiforme, highlighting an emerging public health concern.

In addition, the work of Swedish oncologist Dr Lennart Hardell has been foundational to the International Agency for Research on Cancer (IARC) classification. In 2011, IARC classified the entire radiofrequency electromagnetic field spectrum, including mobile phones, phone masts, Wi-Fi, and smart meters, as a Group 2B “Possible Human Carcinogen.” This classification followed a rigorous scientific review of human, animal, and mechanistic studies and was approved by a nearly unanimous vote: 29 in favour, 1 against. Hardell has stated unequivocally: “The agent is carcinogenic to humans.”

Recent French Data on Cancer Trends in Adolescents and Young Adults

A 2025 study by Santé Publique France (EPI‑AJA) covering 54,785 adolescents and young adults (15–39 years) in 19 French departments found a +6% per year increase in glioblastoma, alongside rising incidences of Hodgkin lymphoma and kidney, breast, and colorectal carcinomas between 2000 and 2020. The study highlights ongoing increases in aggressive cancers in this age group and underscores the need to investigate environmental risk factors and apply precautionary measures to protect vulnerable populations.

Context on the WHO Process and Independent Scientific Critique

The International Commission on the Biological Effects of Electromagnetic Fields has highlighted methodological limitations and underestimation of risk in several WHO systematic reviews, noting the WHO EMF project’s longstanding reliance on ICNIRP. Against this backdrop, the WHO cancer review, incorporating the NTP and Ramazzini animal studies, provides clear evidence of carcinogenic risk, and independent critiques reinforce the strength and relevance of these studies, underscoring the need for precautionary governance and the full consideration of independent research and real-world cancer trends.

Landmark Findings from the European Union REFLEX Project

While UKHSA notes that extrapolating cancer risk from animal bioassays to humans is complex, this does not diminish the relevance of the findings. The Ramazzini studies, which used lower, mast-like exposure levels, produced the same clear evidence of cancer as the higher-exposure NTP studies.

The European Union REFLEX project (2000–2004) further demonstrated that non-thermal RF exposure can cause DNA damage and genotoxic effects in human cells,equivalent to over 1,600 chest X-rays after just 24 hours of mobile phone radiation. REFLEX involved twelve laboratories across seven countries and received €3.1 million in European Commission funding. Despite attempts to discredit the research, court rulings in Hamburg (2015) and Bremen (2020) confirmed that the findings are valid. These results provide direct evidence in human tissue that aligns with animal bioassay findings, reinforcing the plausibility of RF-related cancer risk and the need for precautionary governance.

Furthermore, Dr Henry Lai has assembled a collection of around 2,500 peer‑reviewed studies on the effects of radio‑frequency and extremely low‑frequency electromagnetic fields, freely available via Safer EMR.

Many governments and industry‑funded scientists continue to insist the evidence is “inconclusive” and claim that more research is needed before any health warnings or stricter limits can be justified.  Dr Lai’s database makes it clear that the evidence is overwhelming and strongly challenges that view. 

Concerns Regarding GOLIAT Project and Professor Frank de Vocht

It has come to our attention that Sefton Council is “waiting on” the results of the GOLIAT 5G project, coordinated in part by the University of Bristol. Professor Frank de Vocht is a lead investigator for this project and is also listed as an ICNIRP Commissioner. Publicly, Professor de Vocht recently commented on evidence submitted by the EM Radiation Research Trust to the UK Parliamentary Inquiry on digital identification systems, ridiculing our evidence and referring to the Trust as an “activist” organisation. For clarity, the EM Radiation Research Trust is a registered United Kingdom charity. Both trustees live with electromagnetic sensitivity and have faced repeated health challenges related to cancer. Our work is supported by a distinguished group of independent scientific, public health, and technical advisors who provide guidance in good faith and without prejudice. It is concerning that the Council appears to be awaiting results from a project led by an ICNIRP Commissioner.  

Legal Position of UKHSA Guidance

UKHSA guidance is not legally binding and does not relieve the Council of its statutory obligations, including:

  • ◆ Duty of care to residents
  • ◆ Human rights obligations under Articles 2 and 8
  • ◆ The requirement to apply the Precautionary Principle

Reliance solely on UKHSA summaries or ICNIRP, without consideration of warnings from independent scientists and primary evidence demonstrating cancer, reproductive risks, and other health impacts, is insufficient to meet statutory obligations. Premature claims of safety are both scientifically and procedurally unsound. Six Italian courts have found that mobile phone use was linked to brain tumours, granting legal recognition to RF-related health harms. These rulings explicitly noted that regulators relied on ICNIRP guidance and raised concerns about conflicts of interest.

Requested Actions
Please confirm:

  • ◆ How the Council is incorporating primary evidence on cancer, reproductive, and other health impacts into policy decisions.
  • ◆ That planning decisions will reflect the full weight of current and emerging scientific evidence.
  • ◆ How the Precautionary Principle is being applied in light of these findings.
  • ◆ That the Council will not rely exclusively on UKHSA and ICNIRP guidance when independent scientists and primary research indicate potential risk.

Final Statement

Ignoring independent research and relying solely on ICNIRP guidance is insufficient to meet Sefton Council’s statutory obligations and risks undermining public trust. The Council must exercise its responsibilities transparently and rigorously, ensuring that planning and public health decisions reflect the full weight of current and emerging evidence, including independent scientific research and real-world cancer trends. Under the European Electronic Communications Code (EECC), competent authorities are explicitly required to consider health protection in the deployment of radiofrequency infrastructure. We therefore formally request that the Council confirm its status as a competent authority under the EECC and provide details on how it is fulfilling these duties, including the application of the Precautionary Principle.

The Council has a statutory responsibility to base decisions on the evidence itself, particularly when public health may be at stake. Prematurely closing correspondence while primary evidence indicates potential harm is inappropriate. Given the significance of current and emerging scientific findings, including legal rulings, this information will be made public to ensure transparency and preserve a historic record, so that future decisions are fully informed by the evidence. 

Yours faithfully,

Eileen O’Connor
Co-founder and Director, EM Radiation Research Trust

Brian Stein CBE
Chairman, EM Radiation Research Trust

Radiation Research Trust,
Chetwode House,
Leicester Road,
Melton Mowbray,
Leicestershire,
LE13 1GA
UK