STATE OF NEW JERSEY 1
2 3
BOARD OF PUBLIC UTILITIES 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 : IN THE MATTER OF THE PETITION OF : PUBLIC SERVICE ELECTRIC AND GAS :
COMPANY FOR A DETERMINATION :
PURSUANT TO THE PROVISIONS OF :
N.J.S.A. 40:55D-19 : BPU DOCKET:
: EM09010035
(SUSQUEHANNA-ROSELAND) :
__________________________________________: TO THE HONORABLE COMMISSIONERS OF THE NEW JERSEY BOARD OF PUBLIC UTILITIES:
REBUTTAL TESTIMONY OF WILLIAM H. BAILEY, Ph.D
ON BEHALF OF PUBLIC SERVICE ELECTRIC AND GAS COMPANY IN SUPPORT OF SUSQUEHANNA-ROSELAND
TRANSMISSION LINE PROJECT
I. BACKGROUND
Q. Did you submit direct testimony in this proceeding?
A. Yes I did. In my direct testimony I explained the current state of the science regarding potential health risks associated with exposure to electrical facilities, including exposure to electric and magnetic fields (“EMF”). I discussed the fact that the Project will produce electric fields well below the New Jersey Department of Environmental Protection interim limit at the edge of the right-of-way as well as the fact that the expected EMF levels outside the right-of-way will be below those limits recommended in exposure guidance by international scientific organizations. Additionally, I reviewed the standard scientific method for assessing exposure to EMF and related potential health effects. Summarizing the
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
evaluations of the overall evidence presented by scientific agencies, my direct testimony reflects the consistent conclusions of multidisciplinary scientific review panels that long-term exposure to magnetic fields is not a known or even likely cause of any adverse health effect. I further explained that the conclusions reached by national and international scientific and health agencies from their evaluation of EMF research and the guidelines for exposure they have recommended, make clear that exposures to EMF that people encounter in their daily life, including those from transmission lines like the one considered here as part of the Project, do not pose any recognized long-term health risks.
Q. For the record, please restate your credentials.
A. I earned a Ph.D. in neuropsychology from the City University of New York and received two additional years of postdoctoral training in neurochemistry at The Rockefeller University in New York. My education includes a BA from Dartmouth College in 1966 and an MBA from the University of Chicago, awarded in 1969. Since 1986, I have been a visiting research scientist at Cornell University’s Weill Medical College. I also have been a visiting lecturer at Rutgers University, the University of Texas (San Antonio), and the Harvard School of Public Health in the field of bioelectromagnetics. From 1983 through 1987, I was head of the Laboratory of Neuropharmacology and Environmental Toxicology at the New York State Institute for Basic Research. For the nine previous years, I was an Assistant Professor and Postdoctoral Fellow in Neurochemistry at The Rockefeller University.
Q. Have you served as a reviewer and scientific advisor on health-related issues for State and Federal agencies or scientific organizations? If so, please describe.
A. Yes. I have reviewed research for the National Institutes of Health, the National Science Foundation, and other U.S. federal agencies. Regarding transmission lines specifically, I served on a Scientific Advisory Panel convened by the Minnesota Environmental Quality Board to review health aspects of a high-voltage transmission line. In addition, I served as a consultant on transmission line health and safety issues to the Vermont Department of Public Service, the New York State Department of Environmental Conservation, the staffs of the Maryland Public Service Commission and the Maryland Department of Natural Resources. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
I also have worked with the National Institute of Occupational Health and Safety, the Oak Ridge National Laboratories, the U.S. Department of Energy, and the Federal Railroad Administration to review and evaluate health issues related to electric and magnetic fields (“EMF”) from other sources. I also assisted the U.S. EMF Research and Policy Information Dissemination (“RAPID”) Program to evaluate biological and exposure research as part of its overall risk assessment process.
Most recently, I worked with scientists from 10 countries to evaluate possible hazards from exposures to static and extremely low frequency (“ELF”) EMF for the International Agency for Research in Cancer (“IARC”), a division of the World Health Organization (“WHO”) located in Lyon, France. I also was an invited participant in the workshop convened in March 2006 by the International Committee on Non-Ionizing Radiation Protection (“ICNIRP”) to update guidelines for human exposures to alternating current (“AC”) EMF.1
Although major research programs in the U.S. on the biological effects of EMF have ceased, I continue to evaluate research, funding, and policy initiatives in the field of bioelectromagnetics for government agencies in Canada, the Netherlands, and for scientific journals.
1
ICNIRP recently published updated draft guidelines for comment but the Reference Levels to which exposures are compared to determine compliance are unchanged from its 1998 guidelines, which I described in my prefiled testimony at pp. 8-9.
Q. Have you had the opportunity to review the pre-filed direct testimony of Martin Blank, Ph. D. submitted on behalf of the Fredon School District and Willow Lake Day Camp?
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
A. Yes, I reviewed the testimony of Dr. Martin Blank.
Q. Are you aware of whether Dr. Blank’s conclusions are consistent with the majority of the scientific community?
A. Dr. Blank’s conclusions are not consistent with the conclusions of the expert panels that have reviewed the research on EMF and health for numerous national and international scientific agencies.
Q. On page 1 of his testimony Dr. Blank opines that “there are growing concerns about the health risks” of EMF based on biological mechanisms. Does this opinion accurately reflect the course of health research on EMF over the past 30 years?
A. No. Thirty years ago, there were many unanswered questions about EMF that prompted the scientific community to initiate research to fill in data gaps. This research has addressed many of the questions raised, and the variety and depth of the research has not found consistent or strong evidence of harm to humans. Despite all the research performed to date, there is little data to confirm the many hypotheses about biological mechanisms that have been proposed, including those proposed by Dr. Blank.
II. Health Claims Based Upon In Vitro Studies of “Stress Proteins” and DNA Q. On page 2, and again on pp. 11-12, Dr. Blank argues that EMF initiates the
synthesis of stress proteins, and the synthesis of stress proteins involves the separation of DNA strands, and therefore concludes that EMF interacts with DNA and can cause damage at high intensities. Is this a perspective supported by most research performed in this area?
A. No. All body functions, including the normal response to any environmental or physiological condition, causes a change in the synthesis of proteins and separation of DNA strands.
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2
Normal, essential processes are not harmful just because they make use of DNA. Moreover, Dr. Blank assumes that the stimulation of ‘stress proteins’ must result in some type of negative stress to cells in the body; he has not seriously considered, however, the possibility that magnetic fields might stimulate this protective response directly and not as a secondary result of damage. More important, the weight of the evidence does not support his hypothesis that magnetic fields stimulate the gene expression and production of stress proteins.
Q. Are you aware of any instances where Dr. Blank has advocated for the use of 60-Hz magnetic fields in therapeutic applications?
A. Yes. Although he did not reference this in his direct testimony, Dr. Blank and his colleagues have, in fact, advocated for the use of 60-Hz magnetic fields at an intensity of at least 80 mG in therapeutic applications to stimulate the production of stress proteins as a means of protecting tissues against the harmful effects of a lack of oxygen to the heart (George et al., 2008).
Q. Is there a consistent body of evidence that supports Dr. Blank’s hypothesis regarding the effect of magnetic fields on stress proteins?
A. No. For example, the recent review of research on the responses of cells to magnetic field by scientists for the WHO concludes:
There is no clear evidence of the activation of genes associated with the control of the cell cycle. However, systematic studies analyzing the response of the whole genome have yet to be performed. Many other cellular studies, for example on cell 2
The genetic information in a cell that provides a blueprint for its functions are encoded in twin stands of DNA. When a cell begins to synthesize proteins, the DNA is split apart and the two strands of DNA serve as a template for mRNA that in turn is ‘read’ to produce amino acids, chains of amino acids, and then proteins.
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29
proliferation, apoptosis, calcium signaling, intercellular communication, heat shock protein expression and malignant transformation, have produced inconsistent or inconclusive results. (WHO, 2007, p. 347).
Dr. Blank’s testimony does not provide an objective discussion of the scientific research on the responses of isolated cells to magnetic fields; he almost exclusively cites studies published by himself and his collaborators. He does not cite or discuss the many failures of other independent scientists to replicate the basic phenomena underpinning his hypotheses as discussed below. He, therefore, presents a misleading picture of the research and overstates the reliability of the experimental observations. As summarized by the WHO above, the effects of magnetic fields on heat shock gene expression are very controversial and not as robust as Dr. Blank’s testimony implies.
Other scientists have failed to observe an increase in the expression of heat shock protein in cells exposed at 63 and 80 mG (Morehouse and Owen, 2000), 0 to 1,000 mG (Coulton et al., 2004), at 1,000 mG (Parker and Winters, 1992; Shi et al., 2003), at 34,000 mG (Tsurita et al, 1999), at 3,000-30,000 mG (Kang et al., 1998), and at 50,000 mG (Miyakoshi et al., 2000). Pipkin et al. (1999) reported a response at 10,000 mG, but not at 1,000 mG. This presentation of these results is not meant to be a complete review of the existing data, but rather a listing of findings to demonstrate the inconsistency in the research, which Dr. Blank failed to characterize.
Q. Did scientists initially take the studies of Dr. Blank and his colleagues seriously?
A. Yes, scientists had long searched for a biological response to magnetic fields at low levels without success, and the initial studies of Goodman and Blank on the expression of genes encoding stress proteins and especially cancer-related genes in HL-60 human leukemic cells pointed to the possibility of a biological response at relatively low exposure levels. And, as a result of controversy as to whether
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30
the observed responses might lead to effects on health, quite a number of other scientists began to investigate their reports (e.g., as noted above). In fact, the U.S. EMF RAPID program funded Dr. Russell Owen and his colleagues at the U.S. Food and Drug Administration to design a special exposure system and to attempt to replicate a number of controversial in vitro study results, including those of Dr. Blank and his colleagues. Despite extraordinary measures to ensure that the exposures, cells, and methods faithfully replicated those used in the Blank et al. studies (Boorman et al., 2000), Dr. Owen reported that they were unable to observe any effect of magnetic field exposure on HL-60 cells (Morehouse and Owen, 2000; Owen, 1998).
The EMF RAPID program also funded Dr. Balcer-Kubiczek to search for genes in HL-60 cells that might be responsive to 60-Hz magnetic field exposures. Balcer-Kubiczek and her colleagues reported in 2000 that none of a sample of 1,920 randomly selected genes of HL-60 cells was responsive to a 20,000 mG magnetic field, while about 1% of the genes were responsive to X-rays for which there is evidence for a causal relationship with childhood leukemia (Belson et al., 2007). Similarly, still other investigators reported an inability to replicate Dr. Blank’s claims for the increased expression of certain other genes in HL-60 cells, e.g., Lacy-Hulbert et al. (1995); Lacy-Hulbert et al., 1998; Saffer and Thurston, 1995; Shi et al., 2003).
One review that compared the results of Dr. Goodman’s and Dr. Blank’s work on HL-60 cells to other laboratories noted a prominent difference in the procedures followed – the laboratories that reported no effect of magnetic fields had taken effective steps to prevent experimenter bias by coding the samples so that the scientists analyzing the data had no means of knowing which samples had been exposed to magnetic fields or administered sham exposures until the conclusion of the experiment (Berg, 1999). Another review attributed the positive results obtained in HL-60 cells in Dr. Blank’s laboratory and the lack of effect in other laboratories solely to systematic error introduced by experimental protocols and quantification methods (Lacy-Hulbert et al., 1998). Later studies performed by
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Dr. Blank and his colleagues to explain the failure of other laboratories to replicate their findings (Jin et al., 1997) did not report that they had taken any steps to address the concerns raised about the effectiveness of blinding Dr. Blank’s team to the exposure conditions during the conduct and analysis of the experiments. Such blinding provides protection against experimenter bias, i.e., the results are influenced because the experimenter favors a pre-conceived outcome (Sackett, 1979).
Q. At p. 2, Dr. Blank suggests that structural changes in DNA – mutations – are associated with cancer. Did he test whether magnetic fields actually damage DNA in his studies?
A. His studies did not include tests for DNA damage (i.e., mutations), which would indeed be relevant to the assessment of potential cancer risks. Other scientists have conducted such tests and the results, in aggregate, do not suggest a genotoxic effect of magnetic fields. In 1999, the National Institute of Environmental Health Sciences (“NIEHS”) concluded that there was “no conclusive evidence that genotoxic effects result from ELF- EMF exposures” (p. 26). After evaluating eight more years of research on this topic, the WHO Task Group summarized their discussion of research on DNA damage by stating, “Generally, studies of the effects of ELF magnetic field exposure of cells have shown no induction of genotoxicity at fields below 50 mT [500,000 mG]” (p. 26).
Subsequent to the publication of the report by the WHO Task Group, scientists at Health Canada reported that human subjects exposed for 4 hours to magnetic fields of 2,000 mG did not exhibit any evidence of greater DNA damage in their blood than that obtained from controls (Albert et al., 2009).
III. Relevance of In Vitro Tests to Human Health
Q. Dr. Blank cites his research and other biological studies on pp. 7-8 including a listing of “Biological EMF Thresholds” for 60 Hz magnetic fields. What relevance do these studies have to the assessment of human health risks?
A. Dr. Blank speculates that his research and other biological studies he cites, which focus exclusively on chemical reactions and isolated cells exposed to magnetic fields in vitro, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 3
support the idea that “even weak magnetic fields are biologically active” (pp. 2-3, p. 6, p. 8) and such data support “the plausibility of a link… with childhood leukemia, and the possibility of other diseases” (p. 14).
There are two problems with his argument. First, he does not understand the general limitations of the data he cites as they might apply to human health risk assessment. Only under limited circumstances, which are not met by his research, can in vitro studies provide useful information of direct relevance to human health. For this reason, the IARC and other health agencies regard data from in vitro studies as “other” data subsidiary to data obtained in whole animal and human studies. (e.g., IARC 2002).
Reasons for why it is inappropriate on the grounds of general risk assessment principles to interpret Dr. Blank’s in vitro studies listed on p. 8 as indicators of human health effects, even if they could be replicated reliably, include the following: 17 18 19 20 21
• Chemical reactions outside of cells
The effect of a magnetic field on the chemical reactions he cites on the top of p. 8 of his testimony was measured in the absence of any living cells. He has not shown that a magnetic field of similar intensity would indeed affect these reactions within a cell, or more important, a living organism. • Species and tissue differences
22 23 24
One of the stress response thresholds that Dr. Blank reported in the table on p. 8 was measured in the isolated salivary glands of fungus-eating gnats 3
All of the following citations in Dr. Blank’s testimony are to in vitro studies: citations to biological EMF thresholds in the table on p. 8; energy to stimulate a stress response on pp. 11-12; studies by Lin et al (2001), Blank and Goodman (2004) and Blank (2008) cited on p. 12, which are Exhibits E, F and G to his testimony; and the study by Liburdy et al. (1993) cited on p. 13 of Blank’s testimony.
(Sciara coprophila) The source for this study according to Dr. Blank was the Bioinitiative report, section 7 (Response to PSE&G Interrogatory 28). Yet, the publication cited in that document (Goodman et al., 1994) only describe studies of HL-60 cells and yeast cells (Saccharomyces cerevisiae). Like previous studies by Dr. Blank and colleagues, this claim for increased transcription of stress proteins in yeast too has failed to be replicated (Nakasono et al., 2003). While most toxicologists are cautious about extrapolations even between mammalian species (i.e., humans, monkeys, dogs, cats, rodents), Dr. Blank is undaunted about direct extrapolations from insects and yeast to humans and from responses of insect salivary glands to the origins of human leukemia.
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29
Furthermore, extraordinary claims for effects of EMF at incredibly low exposure levels are meaningless unless their validity has been established by rigorous verification and replication. Despite Dr. Blank’s assertions that his studies show biological responses to magnetic fields at very low magnetic field levels, the NIEHS concluded, “Convincing evidence for causing effects is only available for magnetic flux densities greater than 100 µT [1000 mG]… To date, there is no generally accepted biophysical mechanism by which actions of lower intensity ELF-EMF exposures, including those reported to be of concern in epidemiology studies, might be explained” (NIEHS, 1999, p. 26). Furthermore, this conclusion is contrary to Dr. Blank’s implication at the bottom of p. 7 in response to Q. 9 that the NIEHS based its evaluation of the statistical associations between childhood leukemia and magnetic field levels exceeding 3-4 mG on “data on plausible mechanisms” obtained from laboratory research.
IV. Claims regarding the Interpretation of Human and Animal EMF Studies Q. Dr. Blank also makes claims for the effects of EMF on the secretion of
melatonin and therefore a relationship to breast cancer (p. 2, p. 12). Does the scientific community agree with this claim?
1 2 3 4 5 6 7 8 9 “ 10 11
The results of volunteer studies as well as residential and occupational studies suggest that the neuroendocrine system is not adversely affected by exposure to power-frequency electric and/or magnetic fields. This applies particularly to the circulating levels of specific hormones of the neuroendocrine system, including melatonin, released by the pineal gland, and a number of hormones involved in the control of body metabolism and physiology, released by the pituitary gland (p. 6).
Moreover, the WHO Task Group determined
The scientific evidence supporting a linkage between exposure to ELF magnetic fields and any of these diseases is weaker . . . (for example, for cardiovascular disease or breast cancer) the evidence 12
13 is sufficient to give confidence that magnetic fields do not cause 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
the disease. (p. 351). [Emphasis added]
Therefore, the scientific evidence is inadequate to support Dr. Blank’s claim. Q. Dr. Blank cites a study by Yang et al. at pp. 13-14 and appended as Exhibit I
as providing epidemiologic evidence for a relationship between EMF, DNA damage and childhood leukemia. Does the study by Yang et al. provide data to support this relationship?
A. No, it does not. Dr. Blank misunderstands the design and findings of this study. The study by Yang et al. provides data on the statistical association between a select group of DNA repair alleles and distance from power installations in a group of children with prevalent leukemia. Thus, it only provides data on whether certain alleles were statistically more likely in children with leukemia living near power lines, compared to children living at a distance from the lines. Although a positive association between distance and one specific gene was reported in this study, the study does not provide any information to draw conclusions about gene-magnetic field interactions in the etiology of childhood
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
leukemia. Specifically, there are no data to support the assertion by Dr. Blank on pp. 13-14 that “children missing the DNA repair genes were found to have a 4 fold greater incidence of leukemia from exposure to EMF as low as 1.4-1.8 mG.” Q. Have you reviewed the recent study by Huss et al. from the American
Journal of Epidemiology, which is referenced on p. 13 of Dr. Blank’s direct testimony and appended in Exhibit H?
A. Yes, I have reviewed the recent study by Huss et al. (2009) on neurodegenerative diseases and residential distance from power lines in Switzerland.
Q. What were the results of this study? What is the meaning of these results? A. The authors reported that persons living within 50 meters of high-voltage
transmission lines for at least 10-15 years were statistically more likely to have died from Alzheimer’s disease, compared to those living farther than 600 meters. Overall, the study was carefully conducted and there can be reasonable confidence that bias did not play a large role in the findings. The study is inherently limited, however, if an attempt is made to draw conclusions about magnetic fields from this study. As noted by the WHO and recently confirmed in a study by Maslanyj et al. (2009), distance from power lines is a poor indicator of elevated residential magnetic-field levels.
This limitation, along with others, was recently noted in a letter to the Minister of Housing, Spatial Planning and the Environment from the Health Council of the Netherland’s (“HCN”) Electromagnetic Fields Committee, which stated the following:
The Committee considers the study by Huss et al. on residents near power lines to be of interest … Due to the restrictions stated above, no conclusion on a causal relationship can be drawn from this single study on the relationship between residing in the vicinity of power lines and Alzheimer’s disease: it is not possible to pronounce upon the question of whether this elevated risk is also
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
related to the exposure to the low-frequency magnetic fields generated by the power lines. Even though other studies, such as the one on Swiss railway employees, provide indications of an elevated risk of Alzheimer’s disease in relation to exposure to low-frequency magnetic fields, prospective research is required in order to draw any conclusions. Factors that make an unambiguous interpretation more difficult will have to be controlled in these studies. More information is also required on possible biological mechanisms that could play a role in the effect of low-frequency magnetic fields on the initiation or development of Alzheimer’s disease.
V. The BioInitiative Report
Q. Have you had the opportunity to review the BioInitiative report referenced on page 5 of the direct testimony of Dr. Blank?
A. Yes, I have read the BioInitiative report. The report is a posting to the Internet by
an ad hoc group of 14 individuals who came together to “assess scientific
evidence on health impacts from electromagnetic radiation below current public exposure limits” (The BioInitiative Working Group, 2007). Dr. Blank was one of the contributors to the report.
Q. What is your expert opinion of the BioInitiative report? Are there any limitations to the report? Please explain.
A. I do not place any weight on the conclusions of the report because they are not based on a valid scientific evaluation of the literature. Rather, the report considers select studies, does not evaluate the meaning of the studies’ results by considering the strengths and limitations of the studies, does not properly evaluate the strength of the evidence in support of causality, and does not apply the precautionary principle appropriately when making recommendations. Furthermore, the report does not represent the scientific consensus of a group of
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
experienced experts; rather, the report is a group of chapters written by separate authors and compiled by an individual who is not a health scientist and has no formal education in epidemiology, toxicology, or risk assessment. Since this report was not carried out in an objective, scientific manner, I do not place any weight on the conclusions and recommendations of this report.
Q. Do you believe the BioInitiative Report was an objective report?
A. No, the report was not an objective review of the literature. Select studies were cited from the entire body of literature, which leads one to conclude that studies were selected to support some of the authors’ conclusions.
Q. Are you aware of any scientific agencies criticizing the report? If yes, please explain.
A. Yes, several organizations have commented on the weaknesses of this report, including the European Commission, the German Federal Office for Radiation Protection, the HCN, and the Australian Centre for Radio Frequency Bioeffects Research. Overall, the conclusion of these evaluations was consistent: the BioInitiative report does not represent a sound weight-of-the evidence review; therefore, there is no scientific basis for the conclusions in the report, and no basis for revising exposure guidelines or recommendations related to ELF- EMF. For example, the HCN concluded:
In view of the way the BioInitiative report was compiled, the selective use of scientific data and the other shortcomings mentioned above, the Committee concludes that the BioInitiative report is not an objective and balanced reflection of the current state of scientific knowledge. Therefore, the report does not provide any grounds for revising the current views as to the risks of exposure to electromagnetic fields (p.4).
Q. Can you give us a clear example of the scientific inadequacy of the
BioInitiative report and its ‘cherry picking’ of studies to support the authors’ beliefs? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
A. Yes. A ‘gold standard’ for the assessment of the cancer-causing potential of any chemical or physical agent is whether near lifelong exposure of living animals at very high levels causes excess cancer. Given the recognized importance of such
in vivo studies in assessing cancer risks and in testing theories based upon in vitro
studies, it is surprising that the BioInitiative report did not cite or discuss any of the large in vivo studies performed for the NIEHS (Boorman et al., 1999; McCormick et al., 1999) or by scientists in Canada (Mandeville et al., 1997) or Japan (Yasui et al., 1997). If the theories and speculations of Dr. Blank and his collaborators based almost entirely on in vitro studies were valid, one would expect that exposures to magnetic fields for periods far longer than the few hours or few seconds of the studies that Dr. Blank relies upon would lead to consistent findings of excess cancer in the exposed animals. However, this is not the case (WHO, 2007) and the failure of the BioInitiative report to cite or discuss these very important studies suggests a studied effort of the authors to select studies that appear to support their opinions and disregard those that do not.
Q. Are you aware of the NIEHS Report to Congress on EMF referenced on p. 7 of Dr. Blank’s testimony?
A. Yes, I am aware of this report and have cited some of its conclusions in this rebuttal testimony.
Q. What is your expert opinion of the NIEHS Report to Congress? What was the purpose of the NIEHS Report? Please explain.
A. The report followed standard scientific methods to arrive at conclusions about ELF-EMF and, as a result, I trust its conclusions as a good summary of the status of the research at that time. The report was mandated by the 1992 US Energy Policy Act as part of the EMF-RAPID program, which was a federally-funded
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29
research program to conduct basic health effects research and perform a health risk assessment. The Director of the NIEHS was mandated upon completion of the Program to provide a report outlining the possible human health risks associated with exposure to ELF-EMF.
Q. Please explain what type of scientific evidence results in the classification of “possible carcinogen” by the IARC.
A. The classification “possible carcinogen” falls below “probable carcinogen” and “known carcinogen” and above “probably not a carcinogen” and “unclassifiable” in the IARC classification scheme. It denotes agents for which there is “limited” evidence from epidemiology studies of an association, meaning that there is evidence of a statistical association but other factors (chance, bias and confounding) cannot be ruled out as possible explanations. If these factors could be ruled out with reasonable confidence, then the agent would be classified as a known carcinogen. Also, possible carcinogens have limited or insufficient data in support of carcinogenicity from in vivo studies. Given the inexact and evolving nature of science, many (27%) substances are classified as possible carcinogens, while few are classified as known (11%) or probable (7%) carcinogens. Furthermore, because scientific analysis cannot prove the negative (e.g., that ELF-EMF is completely safe), only one agent has ever been classified as “probably not a carcinogen.”
Q. On page 7 of his testimony, Dr. Blank states that the NIEHS Report recommends that utilities “continue to explore ways to reduce the creation of magnetic fields around transmission lines.” Do you consider low reactance phasing of the conductors a current and reasonable practice for reducing exposures of EMF? Please explain why or why not.
A. It is a standard method for minimizing the field levels outside of rights-of-way with two or more circuits and has been recommended by various regulatory agencies including the Connecticut Siting Council, the Health Protection Agency (“HPA”) of the United Kingdom, and the California Public Utility Commission as
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
an example of a low-cost approach that is consistent with the current state of the research on EMF and health.
Q. Does the NIEHS Report affirmatively state that magnetic fields cause cancer? Please explain.
A. No, the NIEHS report does not conclude or state, in any fashion, that magnetic fields cause cancer. The report appropriately notes that there is some evidence in support of an association between magnetic fields and childhood leukemia and adult chronic lymphocytic leukemia (CLL), but notes that the epidemiology studies provide weak evidence and there is a lack of connection between these findings and the generally negative findings from the highly controlled in vivo
studies. The report concludes that, while magnetic fields could not be recognized as entirely safe, the data does not warrant aggressive regulatory action.
Q. On page 7 of his testimony Dr. Blank references 3-4 mG as the statistical level at which EMF becomes a health issue. Can you explain the basis for Dr. Blank’s reference to 3-4 mG?
A. Two pooled analyses reported a statistical association between childhood leukemia and estimates of average magnetic field exposures at the level of 3-4 mG. Scientific agencies have not concluded, however, that this statistical association represents a causal relationship or that guidelines or actions should be address this average magnetic field level.
Q. Was this 3-4 mG level set as a standard by any governmental or scientific agency?
A. No scientific agency has recommended that 3-4 mG be used as a magnetic-field health standard.
Q. On page 9 of his testimony, Dr. Blank references other issues associated with transmission lines that cause “adverse biological effects.” What is your
opinion of whether radiofrequency noise or ground currents will cause “adverse biological effects” for this Project?
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
A. No scientific or health agency has determined that the there is any evidentiary basis to conclude that radiofrequency ‘noise’ associated with corona on transmission line conductors has adverse biological effects or is harmful to health. Dr. Blank speculates about the presence of ground currents around transmission lines, but presents no evidence that ground currents from transmission lines contribute to the magnetic field exposure of distant residences and cause adverse biological effects.
Q. In your expert opinion, is it appropriate to rely upon one specific type of study when making judgments about potential risks to human health resulting from exposure to electromagnetic fields?
A. No, as I described in my prefiled testimony on p. 10, one specific type of scientific study should not be relied upon to make a judgment concerning potential risks to human health resulting from EMF exposure. Data from several types of studies must be evaluated together in a weight-of-evidence review, including epidemiologic observations in people, experimental studies of humans and animals (in vivo), and experimental studies in isolated cells and tissues (in vitro). Each study type has its unique weaknesses that are addressed by the strengths of the other study types; therefore, all three study types must be considered together in a weight-of-evidence review. The weakness of epidemiology studies, for example, is that they are observational in nature, meaning they are not able to control many of the factors that could possibly affect the outcome; in vivo studies and other experimental studies conducted in laboratories, on the other hand, are designed to control factors that might inadvertently affect the interpretation of the study.
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29
A. Every study varies considerably in the quality of its design and the methods that were used to assess exposure and evaluate impacts. Often, the first group of studies in a field of research uses cheaper and quicker methods to get initial results and, if further research is suggested, more expensive studies with better methods are carried out. It also may happen that, after a study is completed, the investigators find an error that makes the results carry little weight. Scientists cannot draw valid conclusions from studies presenting data that are incomplete or flawed in their methodology, execution, or interpretation. Therefore, it is critically important to evaluate each study individually and give data from studies with a better quality design more weight in a weight-of-evidence review.
Q. Can you provide an example of a recent study completed on the health effects of EMF exposure where it is important to look at the weight of the evidence, rather than the findings of the individual study?
A. A good example of this concept would be the recent study by Huss et al. While this study provides evidence for a statistical association between residential distance from power lines and death due to Alzheimer’s disease, the weight of the evidence does not support a statistical association, or an etiological relationship between magnetic fields and Alzheimer’s disease. This is the first study to consider residential distance (and, by extension, possible residential magnetic field exposure) and neurodegenerative diseases; as a result, no firm conclusions can be drawn until corroboration of the findings occurs. The existing database provides some evidence for an association between Alzheimer’s disease and occupational magnetic field exposure, but the studies are so limited that the scientific agencies consider the evidence as weak. Furthermore, there is no consistent data from experimental studies of a relation between magnetic fields and the development or progression of neurodegenerative diseases. Thus, while considered alone the study by Huss et al. may raise some questions, the cumulative body of research does not provide strong evidence for an association or a causal relationship between magnetic fields and neurodegenerative diseases.
Q. Please summarize the evaluations of the overall evidence presented by scientific agencies regarding possible health effects associated with EMF exposure. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29
A. The following scientific agencies have organized panels to evaluate the research on the potential health effects of EMF exposure: the WHO, NIEHS, IARC, ICNIRP, HCN, the HPA, and the Swedish Radiation Protection Authority (“SSI”). The conclusions of these multidisciplinary scientific review panels regarding ELF-EMF have been generally consistent. None of the panels have concluded that long-term exposure to magnetic fields is a known or likely cause of any adverse health effect and, as a result, no standards or guidelines have been recommended for magnetic fields at the strengths typically encountered in our everyday environments. Magnetic fields were classified as a “possible” carcinogen by several organizations due to the limited epidemiologic evidence related to childhood leukemia and long-term exposure to magnetic fields greater than 3-4 mG and the inadequate evidence from in vivo studies to suggest any possible hazard associated with high magnetic field exposure. Recent reports have recommended further research to try to reconcile the observed statistical association with the negative experimental findings, including research to understand how biases may have affected the statistical association. Researchers will continue to investigate the magnetic field-childhood leukemia association. It is important to note, however, that there are many other hypotheses under investigation that point to possible genetic, environmental, and infectious explanations for childhood leukemia.
Q. Does scientific research show that electric and magnetic fields at levels described in the testimony of PSE&G witness Kyle G. King are harmful to human health?
A. No. The WHO, as well as the numerous other scientific and health agencies that have considered this issue has concluded that, on balance, the weight of the scientific evidence does not support the conclusion that power-frequency EMF
1 2 3 4 5 6 7
causes any long-term adverse health effects. Recent research does not provide evidence to alter this conclusion. The conclusions of the WHO and other agencies apply to all sources of ELF-EMF in our environment, including distribution lines, transmission lines, electrical appliances, and electrically-powered transportation.
Q. Does this conclude your rebuttal testimony? A. Yes it does.
