Words from the ‘regulatory’ authorities

Following on from the Department of Education’s recommendation that I should contact the Australian Communications and Media Authority (ACMA) for more information about the ARPANSA (Australian Radiation Protection and Nuclear Safety Agency) standard, I did so.

I asked ACMA for their opinion on Section 5.7(e) of ARPANSA‘s “Maximum Exposure Levels to Radiofrequency Fields 3 kHz to 300 GHz”, which refers to “minimising, as appropriate, RF exposure which is unnecessary or incidental to achievement of service objectives or process requirements, provided this can be readily achieved at reasonable expense.” Specifically, I asked for an opinion on a body such as the Department of Education running wireless networks in schools, apparently 24 hours, 7 days a week, given the minimisation principle above.

ACMA‘s response was that Section 5.7(e) is outside its remit; ACMA has only been tasked with regulating the devices’ outputs, not when they are used. The email disclaimer does, however, note that “opinions contained in this email or any of its attachments do not necessarily reflect the opinions of ACMA“. ACMA also suggested that I may wish to raise the issue with ARPANSA.

Which I did. I asked ARPANSA who is responsible for ensuring Section 5.7(e) is being adhered to. The response was that ACMA isn’t, and that ARPANSA has no direct role in overseeing the use of wireless technologies. In other words, as far as I can tell, no-one has any responsibility for ensuring that RF exposure is ‘minimised as appropriate’.

ARPANSA also pointed out that 5.7(e) is not intended to apply to de minimis (insignificant) situations, and provided some figures demonstrating that Wifi operates at many orders of magnitude below the standards, with the comment that broadcast AM, FM and TV transmissions are likely dominate. The email concluded by saying that it is, however, reasonable for “the school to implement some minimisation of exposure for the students through good engineering design of the network and sensible classroom habits as regards use of laptop computers”.

I replied that despite the apparently low levels (which studies have shown are actually similar to mobile phones when a laptop is used at close proximity, for example) I still find the situation of interest given that the World Health Organisation has recently classified RF radiation as a possible human carcinogen, and given that we’re talking about institutionalised exposure of children (arguably something we should never regard as de minimis), citing the University of Queensland assessment that showed that 97% of on-campus radiation was actually coming from wifi. I also asked what ARPANSA had in mind as ‘sensible classroom habits’.

My first email to ARPANSA was answered in 6 days. My second email, to the same staff member who answered the first, has been unanswered for over a month.