EM Radiation Research Trust Calls on Sefton Council to Act on RF Exposure, Fire Risks, and Protect Vulnerable Populations
From: Eileen O’Connor, Charity Director, EM Radiation Research Trust
Date: 15 September 2025
To: Sefton Council
I write further to the reply I received at the Sefton Council meeting on 11th September 2025. Both my written questions submitted in advance and my supplementary question delivered verbally highlighted that the WHO/IARC 2025 systematic review confirms RF radiation causes cancer in laboratory animals. This rigorous, gold-standard review, together with the existing IARC Group 2B classification and calls from leading scientists for urgent reclassification to Group 1, underscores the real and immediate public health risks associated with RF exposure.
Despite raising these concerns in both written and verbal form, my questions were met only with the assertion that they had already been answered in response to my previous letter. That is plainly incorrect. Multiple substantive issues remain unanswered or insufficiently addressed, and generic assurances cannot fully address public concerns.
For transparency:
- ♦ Sefton Council and UKHSA response to the EM Radiation Research Trust letter and questions: Link
- ♦Original letter sent on 1st August 2025: Link
This letter, sent today, includes additional information on fire and structural hazards associated with RF infrastructure, including mobile masts. These hazards present real and immediate risks to residents and must be formally considered alongside the well-documented RF exposure concerns raised in my previous correspondence.
1. WHO/IARC Systematic Review – Gold Standard Evidence
Sefton Council has dismissed the 2025 WHO/IARC systematic review (Mevissen et al., 2025) as insufficiently “robust.” WHO-commissioned systematic reviews represent the highest scientific standard and underpin forthcoming Environmental Health Criteria monographs. The review confirms RF exposure causes cancer in laboratory animals, strengthening IARC’s 2011 Group 2B classification and prompting independent scientists to call for urgent reclassification to Group 1 (“known human carcinogen”).
2. Misapplication of ICNIRP Guidance and UKHSA/Sefton Council Assertions
Reliance on ICNIRP compliance and operator assurances, such as the claim that the “general public is prevented from entering exclusion zones,” is legally and scientifically flawed. Many masts are located on rooftops, adjacent to apartment blocks, schools, hospitals, or other occupied buildings, placing residents, workers, and vulnerable populations directly in the path of RF emissions. Physical inaccessibility to the mast base does not eliminate exposure, as ICNIRP guidelines measure only short-term thermal effects and fail to account for cumulative, pulsed, and non-thermal exposures experienced by nearby occupants.
Additional concerns include:
- ♦ ICNIRP explicitly excludes Active Implantable Medical Device (AIMD) users.
- ♦ Many masts in Sefton are publicly accessible, with no barriers or signage.
- ♦ Exclusion zones depend on power output, and operators withholding information cannot be independently verified.
- ♦ Thomas v Cheltenham Borough Council ([2025], Court of Appeal) confirms ICNIRP compliance alone cannot dismiss health objections.
- ♦ ICNIRP addresses only short-term thermal effects, ignoring non-thermal biological effects, cumulative exposures, pulsed signals, and microwave hearing (Council of the EU Recommendation 1999/519/EC).
Reliance on self-certified ICNIRP compliance, sometimes from dissolved or non-existent companies, is unacceptable. Independent, biologically informed review is mandatory.
As noted by Professor Tom Butler in his 2022 report, An Opinion of the Trustworthiness of and Unscientific Bias in the ICNIRP Guidelines 2020, and echoed by Hardell & Carlberg, there have been “missed opportunities for cancer prevention exemplified by asbestos, tobacco, certain pesticides and now RF radiation… Industry has the economic power, access to politicians and media whereas concerned people are unheard.” Link
Taken together with the 2025 WHO/IARC systematic review confirming cancer risks from RF exposure, these warnings make it clear that residents especially children, hospital patients, and other vulnerable groups remain at preventable risk. Despite repeated alerts from independent scientists and public health advocates, our concerns have largely gone unheard, underscoring the urgent need for precautionary, biologically informed policy.
3. Precautionary Setbacks and Vulnerable Populations
Following decades of independent warnings and the Stewart Report (2000), mobile phone masts should not direct their main beam onto schools, hospitals, care homes, or residential buildings without explicit local consultation.
Recommendations:
- ♦ Minimum 500 m from residential areas.
- ♦ Minimum 1,000 m from schools, hospitals, care homes, and other sensitive sites.
- ♦ Vulnerable populations explicitly protected: children, the elderly, electrosensitive individuals, AIMD users, and cancer survivors.
- ICNIRP guidance alone is inadequate; independent, precautionary assessment is required.
- For further guidance, see the Castle Point submission: Link
4. Auditory Effects and Neurological Symptoms
Pulsed RF exposure can induce microwave hearing, tinnitus, and other neurological symptoms even below ICNIRP limits. Councils must assess, monitor, and mitigate these effects near sensitive locations.
5. Fibre-First Principle and Alternative Technologies
FTTP broadband should be prioritised; wireless deployment should occur only where biologically safe exposure can be clearly demonstrated.
6. Fire and Structural Safety Hazards
Faulty installation, overheating batteries, and equipment failures pose immediate risks. Measures must include:
- ♦ Independent fire risk assessments
- ♦ Structural and electrical audits
- ♦ Lithium-ion battery monitoring
- ♦ Transparent reporting and decommissioning of high-risk equipment
Fire Report: 8 November 2024, London
7. Legal and Ethical Governance
Sefton Council must comply with:
- ♦ Gunning Principles: proper consultation, adequate information, sufficient time, and conscientious consideration of responses.
- ♦ Nolan Principles: selflessness, integrity, objectivity, accountability, openness, honesty, and leadership.
Failure to implement precautionary measures undermines these duties and places residents at unnecessary risk.
8. Outstanding Clarifications Required
- ♦ How will Sefton Council incorporate the 2025 WHO/IARC evidence into planning decisions?
- ♦ How will the Council evidence compliance with Equality Act 2010 duties for AIMD users, EHS sufferers, and other vulnerable groups?
- ♦ How will site-specific health objections be assessed substantively rather than dismissed via ICNIRP compliance?
- ♦ Will the Council develop a supplementary planning document (SPD) or internal guidance on telecommunications and public health?
- ♦ What steps will be taken to inspect existing masts and verify protective measures (barriers, signage, setbacks, exposure minimisation, and safeguards)?
- ♦ How will fire and structural safety hazards be formally assessed and mitigated?
- ♦ How will Sefton Council verify and enforce exclusion zones when operators withhold outputs and frequencies, as required under the EECC?
- ♦ Where are the environmental impact assessments for RF infrastructure, and how do they comply with 1999/519/EC?
- ♦ Will Sefton Council review or revoke masts/planning approvals based on incomplete or misleading technical information from dissolved or non-existent companies?
- ♦ How will Sefton Council assess, monitor, and mitigate auditory effects (microwave hearing, tinnitus, and related neurological symptoms) from pulsed RF emissions?
Closing Statement
Sefton Council’s current reliance on ICNIRP guidance and UKHSA assurances does not reflect real-world exposures, particularly for children, hospital patients, AIMD users, and other vulnerable individuals. Until the Council implements:
- ♦ Precautionary setbacks and exposure controls
- ♦ Independent certification of infrastructure based on biologically informed guidance
- ♦ Fibre-first broadband deployment
- ♦ Comprehensive risk assessments (non-thermal, cumulative, pulsed frequency, and peak exposures)
- ♦ Verification of barriers, signage, and exclusion zones
- ♦ Fire and structural safety audits
- ♦ Assessment and mitigation of auditory effects
Sefton Council cannot credibly claim that residents are protected.
I urge the Council to act on precautionary advice and confirm concrete steps to protect Sefton residents, particularly children, hospital patients, and other vulnerable groups.
Yours sincerely,
Eileen O’Connor
Charity Director, EM Radiation Research Trust
www.radiationresearch.org